Your privacy is hugely important to me and 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.
For GDPR requirements, this policy refers to written documents, hard copy client notes, database entries, emails, text messages, visits to my website (www.anjali-leverton.com) and any social media communication.
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.
Owner and Data Controller
‘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: Anjali Leverton, ICO registration reference ZA556587.
Telephone 07484 160971 email email@example.com
If you are not happy with any aspect of how I collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I would be grateful if you would contact me first if you do have a complaint so that I can try to resolve it for you.
My lawful basis for holding and using your personal information
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.
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.
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.
‘Special category personal information’: The lawful basis for me processing any special categories of personal information that might be disclosed to me 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 include name, address and contact details. 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 90 days. If you would like me to delete this information sooner, just let me know.
Accessing counselling: everything you discuss with me is confidential. Confidentiality will only be broken if:
Written Records: I will keep a record of your personal details to help the counselling service run smoothly. These details are kept securely in a locked filing cabinet and are not shared with any third party. I will keep separate, anonymised written notes of each session, these are kept in a locked filing cabinet and are not shared with any third party.
Telephone calls: these are not recorded; however, text messages and voicemail may be stored for the duration of our work together. I may use your phone number to return your call, as per standard business practice.
If we agree to work together your telephone number will be stored with your first name, on my mobile device. In the event that I am unexpectedly incapacitated, only this information will be shared with a colleague so that they can inform you of the situation.
Text Messages: For security reasons I do not retain text messages for more than 90 days. If there is relevant information contained in a text message I will include this in my notes referred to above
Email Correspondence: Any email correspondence will be deleted after 90 days if it is not relevant to our work together. If necessary I will include the details in my notes referred to above. Emails are processed by Microsoft and are therefore subject to their privacy policies. It is recommended that no sensitive information be shared via Email.
Once counselling has ended: Your records will be kept for 6 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.
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 by ensuring that all electronic devices are password protected and encrypted and by ensuring that all paper documents are stored in a locked filing cabinet that only I have access to.
Third party recipients of personal data
I am sometimes required to share personal data with third parties, for example HMRC and ICO or 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.
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 can also ask me at any time to correct any mistakes there may be in the personal information I hold.
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.
To make a request for any personal information I may hold about you, please put the request in writing addressing it to firstname.lastname@example.org. If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me. I would welcome any suggestions for improving my data protection procedures.
Visits to my website
When someone visits my website, I use a third party service, WebHealer/PHD Interactive Ltd 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 WebHealer/PHD Interactive Ltd 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.