PRIVACY POLICY

Privacy Policy

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 explain these below: If you have had therapy 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 or if you are in contact with me to consider therapy, 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 counselling) and necessary for a contract with a health professional (in this case, a contract between me and you).

How I use your Information

Initial Contact

When you contact me with an enquiry about my counselling services, I will collect information to help me satisfy your enquiry. This will your name, address, telephone number, email and your GP and/or Psychiatrist name and address. Alternatively, 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 counselling.

Everything you discuss with me is confidential.  That confidentiality will only be broken if I carefully consider that you in danger of harming yourself or others or there are legal limits to confidentiality, such as acts of law concerning money laundering, terrorism or drug trafficking and in connection with court hearings about which therapists may hold information. I will always try to speak to you about this first, unless there are safeguarding issues preventing this. I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely on password protected machines and a phone exclusively used for my practice which is also password protected. These details are not shared with any third party. I will keep written notes of each session, these are kept electronically and are double password protected and encrypted. For security reasons I do not retain text messages for more than 1 month. If there is any relevant information contained in a text message, I will transfer this to my encrypted notes. Likewise, any email correspondence will be deleted after three months if it is not important. If necessary I will transfer the information to my notes.

After counselling has ended

Once counselling has ended, your records will be kept for 5 years from the end of our contact with each other and are then securely destroyed. If you want me to delete your information sooner than this, please tell me.

Third Party recipients of data

I sometimes share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks. In such cases I have carefully selected which partners I work with. I take great care to ensure that I have a contract with the third party that 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.

Your rights

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 www.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 it

• 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 steven@steventhorntherapy.com.

Complaints about data handling

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 www.ico.org.uk/make-a-complaint. 

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 double passworded files and encrypted devices.

Additional information for website owners and employers
Visitors to my website

When someone visits my website, I use a third party service, Google Analytics 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 Google Analytics 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 Google Analytics so that I can continually improve my service to you, You can read Google Analytics privacy notice here. I use GoDadddy.com as the content management system for my website - find out about GoDaddy.comand data protection. Like most websites we use cookies to help the site work more efficiently - find out about my use of cookies.  No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.

Data Protection & ICO Registration
Steven Thorn Therapy is registered as a data controller with the UK Information Commissioner's Office (ICO)  The registration reference is ZC062668.

Professional Association Compliance

As an Individual Member of BACP I comply with data protection legislation (UK GDPR/Data Protection Act 2018) and the BACP Ethical Framework for the Counselling Professions.