Privacy Policy

My contact details

Organisation: Mind Gardeners Therapy Services

Name: Pippa Menzies

Phone Number: 07376 252245

Introduction

I understand how important your privacy is. I take care to maintain your confidentiality in accordance with current data protection laws (GDPR, 2018) and the ethical guidelines of the British Association of Counselling and Psychotherapy (BACP) These guidelines have been set up to protect your confidential material and ensure that your therapist always conducts themselves with professionalism and integrity.

In order to provide you with the best service possible, I will hold your personal contact details and records of your therapy sessions. 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 talk through any questions you might have about my data protection policy and you can contact me via email at: pippa.mindgardeners@gmail.com.

‘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.

2. 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 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, please let me know.

3. Your personal information

I use the secure, encrypted and password protected practice management platform, Kiku

(wearekiku.com) to collect and store your personal data. At the point of booking your first session with me, you will be asked for your personal contact information, for example your name, address, email address and telephone number and you may also choose to share details of the issues you are looking for help with.

Your contact information is stored securely in Kiku and can only be accessed by me. For more Information about how Kiku stores and protects your data see their Data policy at https://www.wearekiku.com/data and their Privacy Notice at https://www.wearekiku.com/privacy-notices

In order to be able to fulfil my duty of care to you, in your session, I will ask you for contact information for your GP and elected Emergency Contact person. These details will be stored securely in Kiku and will only be accessible to me.

This personal information will be held for the duration of your therapy after which it will be archived on the Kiku database.

Please note that I will need to keep a record of your name and client reference number and clinical notes for seven years after the end of your therapy, in line with requirements from my insurance company, so that we can respond effectively to any potential requests regarding your clinical notes and treatment.

I will never pass on your contact details to any third party organisations for the purposes of sales, marketing or research and will never use your personal data for any purposes other than the administration of the counselling service I providing to you i.e. to arrange, cancel and rearrange appointments and collect payment for sessions.

3. Online Bookings

When you make an online booking or payment, Kiku will send a booking notification to me via email and the Kiku messaging system.

Anonymised payment details are recorded in our Kiku financial income reports. These reports will only hold your first name, last name initial and unique client reference number. The HMRC requires that we retain this information for 5 years after the end of the financial year.

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4. Your payment details

All payments made through Kiku are made through the secure Stripe Connect server. Your information is inputted directly into the card payment portal and no written record of card details will be taken.

If you pay for services by bank transfer, your name and account details may appear on my bank records. If requested, bank statements containing the payee’s name may also be shared with HMRC.

5. Your therapy sessions

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 (see client contract for more details).
Employment, living situation and support: I use this information as part of our client
assessment process, helping me to deliver the best service.
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 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.

During remote working I will ensure that I am conducting online and telephone sessions in a quiet, private and confidential setting. I have selected a video calling platform that offers end to end encryption to ensure maximum privacy. Zoom’s privacy statement can be accessed at https://explore.zoom.us/docs/en-us/privacy.html. Please note however that I cannot be held responsible for any breaches that occur due to failures in this technology.

I discuss my clinical work with a supervisor. This is to ensure that I am offering you the best service possible. These conversations are bound by confidentiality and you will only be referred to by your first name.

I keep notes of each session. These are anonymised and are stored in a locked filing cabinet or within a password protected file within the secure Kiku system (wearekiku.com). These notes are for my use only and help to keep a track of everything that is being discussed. In line with industry guidelines, these notes will be kept securely for up to seven years after your therapy comes to an end. After this time, they

will be confidentially destroyed.

If your sessions are paid for or arranged via a third party, (e.g. your employer, a friend, or a family member), other than payment requests, invoices or receipts your counselling information will not be shared. Details about what is discussed in your sessions will remain confidential between us. Any other information can only be shared if you provide your written consent.

6. After counselling has ended

Once counselling has ended your records will be kept for seven years after our last contact (or seven 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.

7. Your communications with me

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.

My email account is password protected. If you send an email to my email address, only I will have access to it.

All phones, tablets and laptops used to respond to your emails are encrypted, fully protected with anti-virus software and password protected.

8. Data Usage

I will only use your email address and telephone number to contact you about your appointments. I may also contact you directly via email in order to share information with you that is pertinent to your therapeutic process.

Your phone number may also be used to issue appointment reminders via text message. You can opt in or out of text updates using your free Kiku account.

9. 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.
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 completed the contact form, 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 built 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
Google Analytics - Google Analytics is a service that tracks and reports how people interact with and use my service. The service relies on tracking cookies that users must actively consent to receive. Google Analytics uses only usage data. I do not send any personal data to Google Analytics. Google’s privacy policy is available from https://www.google.com/policies/privacy/.
Google Maps - I use Google Maps to display the location of my office for face-to-face appointments and provide directions. When you visit my location pages your IP address is sent to Google. If you ask for directions, you are also sending location data to Google so they can give you the directions you requested. Google’s privacy policy

is https://policies.google.com/privacy?hl=en.

Like most websites my website use cookies to help the site work more efficiently. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of

the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that I store about you may be linked to the information stored in and obtained from cookies.

I use cookies for the following purposes:

Authentication - I use cookies to identify you when you visit my website and as you navigate my website.
Status - I use cookies to help me to determine if you are logged into my website
Personalisation - I use cookies to store information about your preferences and to personalise my website for you
Security - I use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect my website and services generally
Analysis – I use cookies to help me to analyse the use and performance of my website and services
Cookie consent - I use cookies to store your preferences in relation to the use of cookies more generally

My service providers also use cookies and those cookies may be stored on your computer when you visit my website. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary depending on the browser (see https://support.google.com/chrome/answer/95647?hl=en). Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies,

you may not be able to use all the features on my website.

10. Your rights

Any personal data retained by me is kept in accordance with the GDPR, 2018.

Under these guidelines you have the following rights:

1. The right to request access to your data

You can request to view the information that I hold about you (contact details, appointment logs etc.) at any time. If during therapy you would like to see your session notes, please let me know. Should you require a copy of your notes after your therapy has come to an end you can make this request by emailing pippa.mindgardeners@gmail.com or calling 07376 252245.

2. The right of rectification

At any point during your time using my service or during the seven years thereafter, while I retain your records, you have the right to request amendments to your contact details or session notes. This right can be exercised either by speaking directly to me or by contacting me in writing.

3. The right to be forgotten

You can request that I delete and confidentially destroy the information that I hold about you and your sessions at any time. This request can be made by contacting me at pippa.mindgardeners@gmail.com.

Instances where I would not be able to comply with your request are as follows:

a) It is necessary for me to retain these records in order to continue providing an effective service

b) I am compelled to retain these records by a Court of Law

c) I require these records in order to establish, exercise or defend legal claims

11. Consent

When you book your first session with us via Kiku, you will be asked to provide a digital signature and tick a checkbox to confirm that you consent to the storage and processing of your personal data for the purposes of providing therapeutic services.

You are entitled to withdraw this consent at any time and can do so by emailing me

at pippa.mindgardeners@gmail.com.

12. Breaches of data protection

In the event of any breach of my data protection policies, I will notify you and the Information Commissioner’s Office (ICO) within 72 hours and will seek to rectify this immediately.

13. Raising concerns / To make a complaint

If you have any concerns 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 complaint about the way I have processed your personal information please contact me at pippa.mindgardeners@gmail.com. I will acknowledge your message and aim to reply within 30 days. If you are not satisfied with my response, you may escalate your complaint to the Information Commissioner's Office (ICO): https://www.ico.org.uk/make-a-complaint.