Privacy Statement and Data Protection - ADULT


Your privacy is very important to me as a therapist. I take care to protect your confidentiality and personal information. In this, I am bound by the ethics and confidentiality policy of the BACP.
If you do not wish to consent to me storing personal information, you can discuss this with me. We may be able to work something out. However, it would be difficult for me to work with you or provide my best service to you without the option of taking notes to aid my memory.
You have the right to withdraw your consent at any time. I may need to take legal advice on this, in some cases it may not be legally permitted to destroy your records.
You have the right to request access to your records, in writing, and to request alterations.
When I destroy paper records, they are shredded and composted in my home compost bin.
If I discover there has been a data breach that could put you at risk, I will tell you as soon as possible.

Below I set out information on what details I store, how, why and who they are shared with, in a form that meets the compliance requirements for GDPR as I understand them.

Your personal details - name, address, phone number and email
How I keep this
I keep your name, address, email and phone number in paper form in a locked filing cabinet. These are kept separate from your session notes.
A therapist colleague who is my therapeutic executor has your first name and phone number in paper form, inside a sealed envelope, kept in their locked filing cabinet.
My supervisor has your first name with her session notes in a locked filing cabinet.
Why I keep this
So I can contact you. It is also required by my professional liability insurer and by my professional organisation (BACP).
My therapeutic executor has your details so she can inform you of my death or sudden severe illness.
My supervisor has your name so she can oversee my work with you, this improves the quality of my work and helps ensure you are safe.
How long I keep this
Seven years. After that time it is shredded and composted.
My clinical supervisor and therapeutic executor will destroy the data when you and I finish our work.
Who sees this
Me.
My clinical supervisor will know your first name but not your surname or address.
My therapeutic executor will only open the envelope in the event of my sudden death or severe illness.

Electronic Information: your phone number and email address
How I keep this
I keep your phone number in a mobile phone used only for my therapy work under your first name. My phone is locked with a passcode when I am not using it. I do not take it out of my house.
Your email address is held in my counselling practice gmail account (amandahughescounselling@gmail.com), which I am advised is encrypted and GDPR compliant. My computer and phone are password protected, my iPad is fingerprint secured. None of my devices are shared with anyone else, unless it is required by a technician for maintenance.
Why I keep this
So I can contact you.
How long I keep this
Until your therapy ends, unless you give consent to store details in case we work together again in future.
Who sees this
Only me.

Your GP’s name and contact details
How I keep this
In paper form in a locked filing cabinet along with your name and contact details.
Why I keep this
In case I need to contact your GP. Either to inform him/her of your mental health status to keep you safe, as per my confidentiality policy, or to obtain with your consent any relevant medical information that may inform or affect my work with you.
How long I keep this
Until we finish working together.
Who sees this
Only me.

Medical information
How I keep this
In paper form in a locked filing cabinet along with your name and contact details.
Why I keep this
To inform my work with you and keep you safe.
How long I keep this
Until we finish working together.
Who sees this
Only me.

Artworks, sand trays, etc
How I keep this
Your artworks are where possible kept in a locked filing cabinet in my therapy room. Large items are stored securely elsewhere in my therapy room. Your code and date are written on each. I photograph art work and sand trays etc and save as digital images in your session notes.
Why I keep this
To inform my work with you, as per your session notes below.
How long I keep this
When our work together ends, you may take your artworks away. If you choose not to take them, I will dispose of them securely. Digital images will be saved for seven years, along with your session notes, and then deleted.
Who sees this
Me, and possibly my clinical supervisor.

Session notes
My session notes cover date and time of your session, a brief record of key facts shared that day, and themes of the therapy.
How I keep this
Session notes are stored electronically under a code name, eg client A1. Your actual name is not used anywhere in your records, I refer to you as “the client”. The format is Pages documents in the iCloud, which I am informed is encrypted and GDPR compliant. My devices are all password/fingerprint protected, additionally your session notes are secured with an individual password/ fingerprint. I do not store the passwords in my keychain, they are written on your client records stored separately in my locked filing cabinet, and manually entered every time I open your records.
Why I keep this
Brief notes help me remember important points I may refer to in sessions, or want to think about to help me give you my best as a therapist.
How long I keep this
Seven years after our work together ends.
Who sees this
Only me

Payment information
How I keep this
I use a financial app (WaveApps), which is password protected, to record payments using a code (eg client A1). If you pay by BACS, your name and account number will show on my bank statements.
Why I keep this
For tax and accounting purposes, which is required by law.
How long I keep this
I keep financial information for seven years as required by HMRC.
Who sees this
Banking transactions may be viewed by employees of the bank, my accountant, my financial advisor, and tax officers (HMRC).