Privacy Policy for The Therapy Hour 


 1. Introduction

Your privacy is very important to me.

You can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to me. I adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003

This privacy notice tells you what I will do with your personal information from initial point of contact through to after your therapy has ended, including:

  •  Why I am able to process your information and what purpose I am processing it for
  •  Your data protection rights.
  •  Whether you have to provide it to me
  •  How long I store it for
  •  Whether there are other recipients of your personal information
  •  Whether I do automated decision-making or profiling
  •  Whether I intend to transfer it to another country

I am happy to chat through any questions you might have about my data protection policy and you can contact me via email.

‘Data controller’ is the term used to describe the person/organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is me.

I am registered with the Information Commissioner’s Office [Insert registration number].

My email address is: [email protected].

 

 2. Your rights under GDPR

I try to be as open as I can be in terms of giving people access to their personal information. You have a right to ask me to delete your personal information, to limit how I use your personal information, or to stop processing your personal information. You also have a right to ask for a copy of any information that I hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at ico.org.uk/your-data-matters.

If I do hold information about you I will:

  •  give you a description of it and where it came from
  •  tell you why I am holding its, tell you how long I will store your data and how I made
    this decision
  •  tell you who it could be disclosed to
  •  let you have a copy of the information in an intelligible form.

You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you.

To make a request for any personal information I may hold about you, please put the request in writing addressing it to [email protected]

If you have any complaint about how I handle your personal data, please do not hesitate to get in touch with me by writing or emailing to the contact details given above. I would welcome any suggestions for improving my data protection procedures.

If you want to make a formal complaint about the way I have processed your personal information, you can contact the ICO which is the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint. 

 

3. My lawful basis for holding and using your personal information

The GDPR states that I must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which I am processing your data. I have explained these below:

 

  • If you have had therapy or clinical supervision with me and it has now ended, I will use legitimate interest as my lawful basis for holding and using your personal information.

 

  • If you are currently having therapy, clinical supervision, are in contact with me to consider either of these services, or are seeking to access information, training or another advertised product or service, I will process your personal data where it is necessary for the performance of our contract.

 

  • The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for me processing any special categories of personal information is that it is for provision of health treatment (in this case psychotherapy) and necessary for a contract with a health professional (in this case, a contract between me and you).


 4. How I use your information

 

Initial contact

When you contact me with an enquiry about my psychotherapy, supervision or other services, I will collect information to help me satisfy your enquiry. This will include information given to me on your pre-assessment form in order to assess suitability for psychotherapy or counselling. In addition, your GP or other health professional may send me your details when making a referral or a parent or trusted individual may give me your details when making an enquiry on your behalf.

If you decide not to proceed, I will ensure all your personal data is deleted within 3 months. If you would like me to delete this information sooner, just let me know.


While you are accessing psychotherapy or clinical supervision.

Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if it is necessary to do so as outlined at:

Clause 3, page 1 of the Working Agreement for Therapeutic Working Relationship, which you signed on beginning therapy.
Clause 4, page 3 of the Clinical Supervision Contract, which you signed on beginning supervision.

I will always try to speak to you any need to breach confidentiality before doing so, unless there are safeguarding issues that prevent this.

I will keep a record of your personal details to help psychotherapy or supervision to run smoothly. These details are kept securely and are not shared with any third party.

If I keep written notes of any session, these will be kept on my Remarkable2 device under password protected conditions.

For security reasons I do not retain text messages for more than 24 hours. If there is relevant information contained in a text message, I will make a screenshot copy and add it to your securely kept notes. Email and WhatsApp correspondence is kept securely for 7 years after the end of our work together.

Once psychotherapy or supervision has ended your records, will be kept for 7 years from the end of our contact with each other and then will be securely destroyed. If you want me to delete your information sooner than this, please tell me.

Provision and use of other services

Where I request and hold information about you for services other than psychotherapy (e.g to send you asked-for information, products or services), you will formally be asked permission for this to be sent to you and will not receive it unless that permission has been obtained.

Such information will be kept only as long as there is a lawful basis for doing so ie to send you information, products or services and will be securely destroyed after 3 years.  If you want me to delete your information sooner than this, please tell me.

 

5. Third party recipients of personal data


I do not share your personal data with any third party other my therapeutic executor, who holds basic contact details for my clients in case of an emergency. My contract with this individual states what they are allowed to do with the data I share with them. I ensure that they do not use your information in any way other than the task for which they have been contracted.

 

6. Data security

I take the security of the data I hold about you very seriously and as such I take every effort to make sure it is kept secure. I use password protected and encrypted devices and I remove any elements which are insecure as soon as possible.

 

7. Visitors to my website

My website is hosted and maintained by Kajabi LLC, who also carry out a number of web-based services on my behalf in the following ways:

  • When someone visits my website, I use Kajabi to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. I do not make, and do not allow Kajabi to make any attempt to find out the identities of those visiting my website.

  • I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website. 

  • I use Kajabi so that I can continually improve my service to you. You can read Kajabi’s privacy notice at https://kajabi.com/policies/privacy

  • I use Kajabi as the content management system for our website

  

8. Remote sessions

Where requested, I conduct both psychotherapy and clinical supervision sessions remotely using Zoom, WhatsApp or FaceTime for video calls.

In order to be able to take advantage of all its features, I operate Zoom TLS 1.2 with Advanced Encryption Standard (AES) 256-bit algorithm and use their waiting room feature in order to ensure the security and privacy of meetings.

WhatsApp and FaceTime both employ end-to-end encryption to (E2EE).

All these remote services operate and offer their services in a GDPR-compliant manner.

You can read Zoom’s privacy notice at https://explore.zoom.us/en/gdpr/
You can read WhatsApp privacy notice at https://www.whatsapp.com/legal/privacy-policy-eea/?lang=en
You can read Apple’s FaceTime privacy notice at https://www.apple.com/legal/privacy/data/en/face-time/

  

9. Web analytics


I use the web and advertising analytic services of Meta (Facebook) and Google so that I can continually improve my service to you. These companies will deliver relevant content from me based on information about yourself and your pattern of internet use that you have provided them with.

You can read Meta’s privacy notice at https://www.facebook.com/privacy/policy/
You can read Google’s privacy notice at https://policies.google.com/privacy?hl=en-GB

 

10. Payment processing

Processing of payments is handled online by Stripe and offline by Sumup, using industry standard levels of security and encryption of your data.

You can read Stripe’s privacy notice at https://stripe.com/gb/legal/dpa
You can read Sumup’s  privacy notice at https://help.sumup.com/en-GB/articles/2MrnASQDdzJMkFMUnK7BFL-gdpr-data-protection

 

11. Cookies

I use cookies to help my website work more efficiently. A cookie is a small piece of text sent to your browser by any website that you visit. It helps the site remember information about your visit, which can make it easier to visit the site again and make the site more useful to you. You will be given options as to the use of cookies to track your movement when you enter my website. You refuse their use on the site or you can choose to disable cookies through your individual browser options.

  

12. Web forms

If you fill in a form on my website, that information is managed by either by Kajabi, or in the case of pre-assessment forms, by Adobe Acrobat. Both companies will store any data obtained under GDPR-compliant conditions. In the case of Adobe forms, this data will also be password protected. conditions.

You can read Adobe’s privacy policy at https://www.adobe.com/uk/privacy/policy.html

  

13. Transfer of information outside the UK

As international business entities, the companies listed above employ the use of servers which reside outside the United Kingdom. This means your information will be held overseas under the GDPR- compliant conditions maintained by these companies.