GDPR (Privacy) Policy for Counselling Sessions
I am registered with the Information Commissioners Office in the UK (ICO) (security number CSN5986266) and adhere to the GDPR guidelines for the UK and for the EU. As I am self-employed, I operate as the data controller for all my therapeutic work. Please note that I use the terms therapy and counselling interchangeably.
Personal information that I collect
When you contact me and as part of our initial assessment, I will ask you for the following information:
- Name, telephone number, email address, address
- Gender, date of birth
- Key relationships, occupation
- Doctor’s name and address, plus any medical conditions relevant to therapy or that may present in the therapy room, including any prescribed medication
- Emergency contact and their relationship to you
- Counselling history and current reasons for seeking counselling
How I will store your information
• Mobile phone
I will store your contact information (name, mobile number, email address and address – item 1 above) and your emergency contact information (item 5 above) on a mobile phone that is reserved for counselling purposes. This allows me to contact you when necessary but does not allow the information to be shared elsewhere. I use WhatsApp for business on this phone to send messages, so any correspondence between us will be stored there.
All other information collected during the assessment session (items 2-6 above) will be stored electronically on a password-protected laptop that will be kept in a locked filing cabinet in my home or office. This laptop utilises two-part verification for all external purposes (enhanced security measures).
I usually make brief notes after each session and sometimes during supervision (see section on supervision below). I will store your anonymised session notes in a file (identified only by your initials). This will be kept on my laptop or on paper, but always in a locked filing cabinet in my home or office when not in use.
• Email/text messaging/WhatsApp
Any emails you send me will be saved as a PDF and stored on my laptop, then deleted from my email account.
Any text messages or WhatsApp messages will be stored on my phone until they are deleted by me (usually by the end of our last session together). Electronic correspondence will also be held by whatever method you use to contact me, unless/until you delete it yourself (e.g. by WhatsApp, by your email provider or on your phone).
• Virtual counselling
Should we use any virtual or distance methods of counselling, such as telephone or video conferencing, there will be a record of when the calls were made, but no information about what is discussed will be recorded or saved by me.
If we carry out any sessions via email/messaging (as above), the content of the session(s) will be stored on my laptop as a PDF and deleted from my email once the session is over. I use a password-protected account on my computer for my counselling work, separate to my personal account. My email is dedicated to counselling work and only available via this password-protected account on my computer. This ensures no overlap between personal and professional use of my electronic devices.
None of your personal information is stored on my website.
How I may share your personal information
All UK therapists are required to attend monthly supervision with another therapist who is qualified in supervision (a supervisor), and who adheres to the same ethics and confidentiality requirements as therapists.
The supervision process is to ensure the highest standards in my practice. It is about how I work with you. In order to protect your privacy, my supervisor will not know you personally or professionally. I will refer to you only by your first name, and I may refer to your information when it’s helpful to my professional practice and to how I can best support you. None of these conversations are recorded, though I may make notes for my own use.
Not all countries require that therapists undertake supervision. I trained and first practiced in the UK, and I have chosen to continue with this practice in Sweden, as I believe it significantly improves therapeutic practice and therefore my support of my clients.
• Therapeutic Will
Your name and contact details will be shared with my Therapeutic Executor. This is so that should I die unexpectedly while you are still in therapy with me, you will be contacted and offered alternative support.
With your consent wherever possible, if I am seriously concerned about you or your health, I may share your contact information with an emergency healthcare service (e.g. the health service on 1177 or Norra Stockholms psykiatri on 08-123 400 00).
If you share with me your intention to cause harm to another person or organisation (e.g. terrorism), I may be legally required to inform an authority without seeking your permission. In such a situation, I may also be required to share your personal information without your knowledge.
How long do I hold your information?
When we have finished working together, I will delete electronic copies of your information and correspondence within one month. I will hold onto your session information (written or electronic) for up to seven years past the end of our working together. This is so that I have a reference of our work in situations such as you returning to counselling in the future. After this time has passed, I will shred or permanently delete the session information.
You have the following rights:
- To know what information I hold about you (outlined on this page).
- To see the information I hold about you (free of charge for the initial request).
- To amend any inaccurate or incomplete personal information I hold about you.
- To withdraw consent to me using your personal information.
- To request that I delete any personal information I hold about you (though I can decline if the information is needed for me to practice lawfully and competently).
You can complain to the ICO if you are unhappy with how I have used your data using this contact information: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF // +44 (0)303 123 1113.
I am very happy to explain anything on this page that is not clear to you. Signing the contract confirms your agreement with the terms of the contract, as well as with the terms of the GDPR policy as outlined here.
This document outlines what I have done to ensure the confidentiality of your data and personal information, according to legal requirements. However, it is important to be aware that I do not have control over external software, apps or service providers, including those that you use. As such, it is important that you are happy with the services you use at your end. In addition, there are sometimes rare and unforeseen data breaches over which I have no control, such as hacking incidents.