1. My contact details
Organisation: Mind Gardeners Therapy Services
Name: Pippa Menzies
Phone Number: 07376 252245
Your privacy is very 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. 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, including:
Why I am able to process your information and what purpose I am processing it for
Whether you have to provide it to me
How long I store it for
Whether there are other recipients of your personal information
Whether I intend to transfer it to another country
Whether I do automated decision-making or profiling, and
Your data protection rights.
I am happy to chat through any questions you might have about my data protection policy and you can contact me via email at: firstname.lastname@example.org.
‘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, Pippa Menzies.
I am registered with the Information Commissioner’s Office - Philippa Menzies (Mind Gardeners Therapy Services) ICO reference ZB239646.
3. 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.
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).
4. How I use your information
When you contact me with an enquiry about my counselling services, I will collect information to help me satisfy your enquiry. This will include your name, telephone number and email 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 one month. If you would like me to delete this information sooner, just let me know.
While you are accessing counselling
While you are accessing counselling, I will collect information to help me to provide you with an effective counselling service. This includes the following information (please note, I do not keep all this information for every client and only record and keep the information I need to provide the service):
Name, age and date of birth: this helps me get to know you and identify you.
Address, email address, phone number(s): I need this information to contact you.
Relationship status, partner’s name and how long you been in this relationship: this information helps me understand your current domestic situation.
Doctor and emergency contact details: I have a duty of care towards you and, sometimes, might need an emergency contact. I also might need to contact your GP if, for example, you were at risk of serious harm. Except in the most exceptional circumstances, I would contact no one without your prior knowledge and consent.
Employment, living situation and support: I use this information as part of our client assessment process, helping me to deliver the best service.
School/employer/agency details: I collect this information where a third-party is paying so I can invoice them for the work I do.
Parents, siblings and children: I often need to know something of your background as part of the assessment process.
Broader familial information: Sometimes, I need more extensive family information. This information is necessary to understand the client’s world and, potentially, for child/vulnerable adult protection purposes.
Assessment forms/scores: I might use assessments as an audit of the effectiveness of our work as part of the assessment process.
Session notes: I keep brief, factual notes as a record of our work together.
Recordings of sessions: Sometimes, I might record a session as a record of our work together or for use in clinical supervision and professional development. This would only be done with your explicit and written consent.
Correspondence: I might store copies of any communication as part of your clinical notes.
Referral information: I need to keep third-party referral details for invoicing purposes. I might use some referral information as part of your initial assessment.
Appointment/attendance/fees: Appointment, attendance and payment details are required for scheduling, reporting, invoicing and accounting purposes.
Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if there is a legal requirement to do so, or as set out in our working agreement i.e.:
if you disclose information related to terror or terrorist activities
if you or anyone you identify to us is at serious risk of significant harm
as explicitly directed by a court order or coroner request
according to your explicit, written instruction
in a discharge/progress report, if required, and with your consent
I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
After counselling has ended
Once counselling has ended your records will be kept for five years after our last contact (or five years after you turn 18, whichever is longer) from the end of our contact with each other before being securely destroyed. If you want me to delete your information sooner than this, please tell me.
Personal identifying data (name and contact details) are kept securely in a different system from all other client records (e.g. session notes). All physical documents containing your personal data are kept securely in a locked filing cabinet. Electronic records are kept on a password protected computer system. These records are kept for five years after our last contact (or five years after you turn 18, whichever is longer). I destroy any audio, video and similar recordings after three months. These details are not shared with any third party.
For security reasons I do not retain text messages for more than two months. If there is relevant data contained in a text message, I will add these to your clinical records. Likewise, any email correspondence will be deleted after two months if it is not important, and I will add important data to your clinical records.
I destroy all records by physical or electronic shredding or similar methods of secure destruction.
6. Third party recipients of personal 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.
Microsoft Office 365 – I use Microsoft Office to process personal data electronically (email, storing records etc.).
Email - Communications in connection with my services may be sent by email (gmail). For ease of use and compatibility, communications will not be sent in an encrypted form unless you require it and give me permission to communicate with you in that way. Email, unless encrypted, is not a fully secure means of communication. Whilst I endeavour to keep my systems and communications protected against viruses and other harmful effects, I cannot bear responsibility for all communications being virus-free.
Zoom – I use the Zoom video platform to host online counselling sessions. The data transmitted during meetings are encrypted and secure. Zoom’s privacy statement can be accessed at https://explore.zoom.us/docs/en-us/privacy.html
CCTV – The Old Printworks premises in Eastbourne has CCTV and recordings may, in rare circumstances, be accessed by the building owners for security and legal purposes.
Writeupp – I may use www.Writeupp.com for organising online bookings, invoicing and for keeping brief session notes. Writeupp is ISO27001 accredited, certificate number 275372018.
Payment – If you pay for services by bank transfer, your name and account details may appear on my bank records. Bank statements containing the payee’s name may also be shared with my accountant and, if requested, with HMRC.
7. 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 https://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 its, 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 email@example.com.
If you have any complaint about how I handle your personal data, please do not hesitate to get in touch with me by 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 https://www.ico.org.uk/make-a-complaint.
8. Visitors to my website
When someone visits my website, I use third party services (www.Wix.com and www.godaddy.com) 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 www.Wix.com and www.godaddy.com 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.
The data I collect through my website includes:
Usage data: Every time you interact with my website, you generate usage data. I require this data to make the service work. I do not keep usage data except as below.
Website forms: When you submit a form from my website, the details you entered are sent to me by email and stored on the server. The emails are sent and received using an encrypted connection to protect your data.
Comments: When you leave a comment on my website, I collect and store the data entered in the comments form. I also collect your IP address and browser user agent string to help spam detection.
Embedded content from other websites: Articles on my website may include embedded content (e.g. videos, images, articles, and such like). Embedded content from other websites behaves in the same way as if the visitor has visited the other website. I have no control over the way third-party sites collect or use your data.
If you leave a comment on my website, I keep the comment and its metadata indefinitely. If you submit a form or book using the contact form or online booking system, I store the information provided for as long as required to deliver the service requested.
If you have left a comment on a blog post, completed the contact form or used the online booking system, you can request details of any data I hold. You can also request that I erase any personal data I hold about you. The right to erasure does not include any data I must keep for administrative, legal, or security purposes.
I store and process your data on secure servers. There is no external access to your data. My website is build using industry-standard software, automatically updated to the current release, to help prevent data breaches. I have never had a data breach. If I discover any infringement, I will notify all affected parties as per data protection legislation and best practice.
My website uses the following external services and might share some of your data with them:
Go Daddy and Wix - I use Go Daddy and Wix to host this service. While I do not explicitly share any data with them, they hold and maintain the database upon which this service relies. Their respective privacy policies are available on their websites: www.godaddy.com and www.wix.com