Data Privacy Notice
Amanda (Sam) Hughes
Sam Hughes Counselling
As part of the work we do together it will be necessary for me to hold some information about you. Your personal data is important to me as I know it is to you and I am committed to keeping it safe and treating it with respect. I will only ask you for information that is necessary for me to provide you with a safe, effective therapeutic alliance and for me to provide the highest standard of support to you. My aim is to be as clear as I can be with you about what information I need from you and why:
Terminology
GDPR – the processing of personal data is governed by the General Data Protection Regulation.
I am the Data Controller within the context of GDPR and as such I decide what information to collect about you.
I am also the Data Processor in that it is me who decides how to process, store and use the information I collect about you within the confines of what is both necessary and lawful.
For the purpose of the Data Protection Act 1998 ("the Act"), the data controller is Amanda Hughes and the data protection registration number is ZB069606.
You are the Data Subject within the context of GDPR and as such your data is protected by UK Data Protection Law.
Third Party means anyone else I might share your information with. In general, there will be no need for this ever to happen and certainly not without your permission (see information in your Therapy Contract about confidentiality and breaching confidentiality).
What data will I need to hold about you:
- Name
- Date of Birth
- Gender/Preferred Pro-noun
- Address
- Contact information – email/phone
- GP name and contact number
- Support person contact information
- Any relevant medical information
- Session notes
What is the lawful basis on which I have decided to hold information about you?
The lawful basis for processing your data comes under 2 categories of Article 6 of the GDPR:
Processing is necessary for the performance of a contract - This means that under the terms or our agreement to work together I require certain personal information from you.
Processing is necessary for compliance with a legal obligation - I am required to by the Health Care Professions Council (HCPC) to keep case notes for a period of seven years from the date therapy started. Also, I am required by law to inform the appropriate authorities if you make a disclosure concerning an act of terrorism, or where you or others are at risk of serious harm or abuse. Where possible I will seek your consent.
Processing is necessary to protect the vital interests of you or another person - As above or in the case of an emergency, for example you become unwell during a session and my needing to pass your contact or medical information to the emergency services or to your GP or support person.
Processing on the basis of consent - Where possible I gain consent to process your data and to share it with a third party. However, if you do not consent, in some situations (as outlined below) I may still share your data.
Exceptions and Breaches
Your personal data is strictly confidential. As is the content of your therapy sessions and everything you share with me as part of our work together. There are three possible areas of exception to this though:
Supervision - In order to provide the highest possible standard of therapy I am supervised in my work by a Therapist who is more experienced that me and trained to offer Supervision. Information about sessions is taken to Supervision only as required and is anonymized meaning that I will use only your first name and not disclose any information which could identify you.
Safeguarding and Protection - If for any reason I develop concerns that you, or someone you know, are at serious risk of harm or abuse, or that you intend to harm yourself or another, I reserve the right to take appropriate action based upon my professional judgement. If possible, this will be done with your knowledge and consent. If this is not possible, I will act without your permission to safeguard your wellbeing and that of others.
Acts of Terrorism - In the case of disclosure concerning acts of terrorism and under the terrorism act, confidentiality will be broken, and such disclosures will be passed onto the relevant authority as is my lawful duty.
How will I keep your information secure?
All printed material will be stored in a locked filing cabinet and all electronic files will be password protected. I use a notebook, which I bring to sessions and carry around with me, so I will ensure that any information I write during and after our sessions is anonymised to mean nothing to anyone who could come across it.
Your rights
I will only hold information about you that I need in order to manage our working relationship and provide the highest standard of therapy for you. And there are some legal considerations such as fact that I am required by the Health Care Professions Council (HCPC) to keep case notes for a period of seven years from the date therapy started. But in general, these are your rights:
- You have the right to access information I hold about you.
- You have the right to correct and update the information I hold about you.
- You have the right to have your information erased.
- You have the right to object to the processing of your data.
- You have the right to withdraw consent to the collection and processing of your data.
- The right to lodge a complaint with the Information Commissioners Office (ICO).
Please get in touch if you are feeling that you would like to exercise any of these rights so we can discuss the implications for us both and respond accordingly.
Contacting Me: If at any time you would like to contact me with your views about my privacy practices, or with any enquiry relating to your personal information, you can do so by sending an e-mail to me at counselling@samhughes.co.uk
Registered with the Information Commissioner’s Office (ICO) registration number A8955907