Privacy policy.
Introduction
Your privacy is very important to me and you can be confident that your personal information will be kept safe and secure. It 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) (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 the point of initial contact through to after your therapy has ended.
I am happy to chat through any questions you might have about my data protection policy and you can contact me via dawnamcounselling@outlook.com .
‘Data Controller’ is the term used to describe the person that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is me, Dawn Astle-McDonald.
I am registered with the Information Commissioner’s Office and my registration number is C1353948.
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 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.
What data do I keep and why do I need it?
I collect, store and process personal information about you to enable me to run my counselling/psychotherapy practice and deliver the services you are employing me for. This information can include contact information, as well as information about your age, health (mental and physical), sexuality (where relevant to the therapeutic work), domestic and financial arrangements (where relevant) and other special category data. I collect this information upon the legal basis of “Contract”, as per GDPR regulations. This data will be collected when you contact me to enquire about my services. 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.
Will I share your data and if I do who will I share it with and for what purpose?
Please rest assured that everything you discuss with me is confidential and it is unlikely that I will share your data. I will not sell it on, share it with a third party or use it for unethical reasons. However, I may have to share it if I am required to do so by law (such as Acts of Terrorism, human/drug trafficking, money laundering) or if my notes are subpoenaed by the courts. Also, if you or anyone you tell me about is being harmed or is at risk of harm, I may have to pass this information on to my supervisor, your GP or police. I would always endeavour to discuss this with you prior to taking any action unless there are safeguarding issues that prevent this.
Additionally, in the unlikely event of me being incapacitated, I have nominated a fellow counsellor, Aline Kernan, who has limited access to your data (your name and contact details) so that she can call you. This is common in private counselling and psychotherapy practice and is known as a therapeutic will. It ensures that you are kept informed and assisted if I suddenly become unable to let you know of a change in my circumstances that affects your therapy. Aline is contracted to not share your data with any other party. If necessary, she will also ensure that your data is kept secure and deleted in accordance with GDPR and my insurance requirements.
How will I store your data?
Your identifiable data is kept on paper in a locked filing cabinet. Your anonymised session and assessment notes are kept separately in an online password protected file within my password protected OneDrive. Your phone numbers will be kept in my business mobile phone which is passcode protected. Emails are held in my business Outlook account which is operated, and password protected by Microsoft Office 365. Emails will be deleted after 24 hours if they are not important. If necessary, I will transfer the salient information into your session notes.
If you contact me via the contact form on my website, this information is contained in a separate folder on my website account page, which is password protected and only accessible by me. My website is powered by Squarespace and I do not allow Squarespace to use your identifying information for their purposes. I do, however, use Google analytics (through SquareSpace) to monitor my website’s visitor patterns but this does not use your identifying information. I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.
I do not retain text messages for more than 24 hours. If there is relevant information contained in a text message, I will transfer that to your session notes or identifiable data as appropriate for longer term storage.
Online Counselling
Where online counselling is agreed, this will be offered via MS Teams video/audio or Zoom. You will be asked to state your preference and it is advised that you to check the terms and conditions of your chosen platform to ensure that you are in agreement with their data privacy and usage policies. I attach links below:
MS Teams: Microsoft Teams Privacy - Microsoft Teams | Microsoft Learn
Zoom: Privacy | Zoom
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 For the public | ICO.
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 it 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 and address it to: Dawn AM Counselling, Rownhams House, Rownhams, Southampton, SO16 8LS.
How long will I store your data for and how will I dispose of it?
If you have had therapy with me, I’ll keep your session records and any documentation containing your personal data (including this statement, the assessment and working agreement) for 5 years which is the time frame requested by my insurance company. After 5 years all documentation will be disposed of confidentially and securely. I will delete your phone number out of my mobile phone around one calendar month after our work finishes and emails will also be deleted around one calendar month after our work has come to an end. If you would like me to delete your information sooner, please let me know.
Complaints
If you have any complaint about how I handle your data, please do not hesitate to get in touch by writing or emailing via the contact details above. I always welcome suggestions for improvement.
If you wish to make a formal complaint, you can contact the ICO at Information Commissioner's Office (ICO) or phone them on 0303 123 1113.