In order to provide you with the best service possible, I need to 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 therapy has ended. 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. I also abide by the professional Ethical Framework and guidelines of the British Association for Counselling and Psychotherapy (BACP) and the Professional Conduct and Code of Ethics of The Association for Counselling and Therapy Online (ACTO).
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. 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, therapy sessions) and necessary for a contract with a health professional (in this case, a contract between me and you).
How I use your information
I will never use your personal data for any purposes other than the provision of fully encrypted email counselling and the recording and administration of phone, video or email sessions i.e. to arrange, cancel and rearrange appointments. I will only retain your personal information for as long as is necessary. This is in line with guidance from the Information Commissioner’s Office.
Initial contact
I record client information and communicate with others through Tutanota. Tutanota is an easy to use secure email service with built-in end-to-end encryption and state of the art security features.
Every visitor of my website can contact me confidentially via my Contact Form. Your query will not remain on the website but will be sent to my encrypted email account with Tutanota and the content decrypted for me to see. This Contact Form will provide me with some brief information to help me process your enquiry and to offer counselling services.
With your consent, an organisation such as your employer may send me your details when making a referral or a relative may give me your details when making an enquiry on your behalf. If an enquiry is made and you decide not to proceed I will ensure that all of your personal data is deleted within one month. If you would like me to delete this information sooner please let me know.
Once you’ve contacted me and prior to your therapy starting, I will ask you to complete a Personal Details Form containing your name, contact information, date of birth, demographic, physical and mental health information, GP details, main problem(s) and key historical events.
An ordinary email is not a secure system, so before starting sessions (either phone, video or email sessions), I’d recommend that you register a free and secure email account with Tutanota.com. This is essential if you would like email counselling and ideal also if you are having video consultations or telephone sessions, as I can then send you therapeutic documents relevant to our work together. If you cannot do this yourself, please ask for someone to help you or contact me for assistance. Use of such an email system is in line with the BACP and ACTO guidelines for Online Counselling and Psychotherapy.
You may encrypt this initial document before emailing this back to me if you wish (to ensure data safety in transit). Once it hits my email account however, it will automatically be encrypted. Alternatively, your Personal Details Form can be completed with me over the telephone on 07902 032 413.
Assuming I feel my service would be suitable for you, I would then recommend that you register a free and secure email account with Tutanota.com (as an ordinary email account is not secure).
This is essential if you would like email counselling and ideal also if you are having telephone sessions, as I can then send you therapeutic documents relevant to our work together. If you cannot do this yourself, please ask for someone to help you or contact me for assistance. Use of such an email system is in line with the BACP and ACTO guidelines for Online Counselling and Psychotherapy. If we both use this email provider, you can have peace of mind that your emails and notes will be stored confidentially and read by no one else but me. Even Tutanota cannot access them! Notably, If I am responding to you with a non-Tutanota email address (specifically for Intune Counselling or Song Therapy), this is an Alias and will still be as secure. Aliases are alternative email addresses tied to my usual Tutanota account.
While you are accessing therapy
If you have chosen to receive email counselling, your email address will be used regularly for this purpose (likewise a telephone number for video consultations or telephone counselling) If you are receiving counselling via video call/telephone, your email address or phone number will be used (with your consent) to provide you with written confirmation of your appointment times; contact you about my concerns for you or email you information relevant to your therapy sessions. Email Counselling exchanges are stored in my encrypted Tutanota account as well as brief notes for video/telephone therapy sessions. These notes help me to keep track of our work together and reflect on how best to support you.
It is important to me that my clients feel safe and comfortable. For therapy to be beneficial it is important that we build up trust and that you feel able to speak openly and freely about yourself and your difficulties. Therefore, I believe that it is important for you to be aware of the parameters of confidentiality before you start therapy. Rest assured your confidentiality will be respected and maintained. However, an occasional exception to this may be if I feel you are in some way at risk to yourself or others or if I am required to disclose information to a court of law. In such cases, I will always talk to you first about my concerns before discussing with or involving others, unless there are safeguarding issues that prevent this.
If you suffer from an Eating Disorder, your physical wellbeing may need to be monitored by your medical practitioner alongside our work together and I shall discuss this with you if this is necessary. Unless you are at risk or underweight with an eating disorder and you’ve given me permission to do so, I will not routinely contact your GP to inform your GP of your attendance or request updates of your physical health. To fulfil my duty of care towards you while also maintaining your confidentiality, I will only contact your GP if it is necessary as part of your treatment and should these circumstances arise I would discuss this with you first.
I am required to discuss our work together regularly with a clinical Supervisor. Supervision is an essential part of my practice as it enables me to reflect on and review the quality of sessions and ensures the highest ethical standards are being maintained. Notably, information will be shared in a way which respects your confidentiality (i.e. only using your initials or first name). My supervisor is a counsellor who also abides by the BACP’s code of ethics regarding confidentiality.
After therapy has ended
There are reasons why counsellors are required to keep records after therapy has ended. For example, in the case of financial transactions personal information must be retained for as long as legally required in respect of tax or accounting purposes. Retaining your therapy notes ensures that I can continue to offer you an efficient service if you make contact after therapy has ended. Your therapy notes will be filed with a client reference number (rather than full name) and continue to be encrypted and stored securely in Tutanota for 7 years after you have ended therapy. This time frame adheres to current industry guidelines. If I terminate my account with Tutanota sooner than 7 years, I will retrieve the bare minimum information and keep this in a file on my computer that is password protected.
Please note that a record of your name, dob, and client reference number will be kept for seven years also after therapy ends. These basic details will be kept separate to your electronic notes in a locked filing cabinet that only I have access to. Seven years after therapy has ended your therapy notes/details will be permanently deleted/confidentially destroyed.
Third party recipients of personal data
I share a limited amount of personal data with third parties in order to provide therapy services to you and to fulfil legal obligations in respect of tax and accounting purposes. For example, my accountant is permitted access to my invoices and if we’ve agreed on a face-to-face appointment (which notably, I’m not currently offering), I will give your name to reception in order to book your appointment at that location. I also may occasionally employ a trusted IT contractor to undertake services on my computer and although unlikely, they may come across basic personal data. This person is required to adhere to Intune Counselling’s confidentiality policy and will only access systems on a strict need-to-know basis. I will never pass on your contact details to any third party organisations for the purposes of sales, marketing or research.
If your appointments are paid for or arranged via a third party, for example, your parents or employer the only information shared with the third party is your dates of attendance and non-attendance for invoicing and payment purposes. Details about what is discussed in your appointments will remain confidential and can only be shared if you give me your written consent to do so.
Data security
I take the security of the data that I hold about you very seriously (please see above sections). My email account at Tutanota is end-to-end encrypted and password protected and mobile phones and electronic devices used to respond to my emails are password protected. I also use anti-virus software protecting all data and correspondence.
Website visitors
By accessing Intune Counselling, you are consenting to the information collection and use practices described in this privacy notice. The website uses cookies and Google Analytics. Almost all websites use cookies which are small files that get put on your computer by websites as you surf them. These cookies can store lots of information which can have privacy implications. Google Analytics is a service provided by Google that gathers anonymous data on how people are using websites and then provides visitor statistics, details of page views etc. This service is used by many website owners as the data helps website owners to improve their websites.
Some page elements (such as videos) are embedded from third parties (such as YouTube) in order to provide you with an interesting, Interactive and therapeutic experience on my website. However, most of these come with their own cookies. I do not control these cookies so I cannot guarantee what they do. In many cases, cookies are used to generate identical information to Google Analytics and indeed use Google Analytics, so opting-out of Google Analytics will also opt you out of these cookies too. You can opt out of Google analytics and other Google services here – optout and dashboard.
Your rights
Under GDPR, 2018 guidelines you have the following rights: The right to request access to the personal information that I store and process about you. You can ask for corrections to be made to your personal details held, or for your personal information to be limited or deleted (in some circumstances). You can read more about your rights at ico.org.uk/your-data-matters. If you would like to make a request relating to any of the rights above, please send me a request in writing, either via my contacts page or my Email address if you have received therapy. Please be aware that in certain situations counsellors may be unable to comply with the above requests. For example, if compelled to retain the records by a court of law. Please also be aware that there may be a charge for complying with a request if it is deemed to be excessive in nature.
Queries
‘Data controller’ is the term used to describe the person or organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is Erin Halil and I am registered with the Information Commissioner’s Office: the registration number for Intune Counselling is ZB019219. If you have any questions about this privacy policy or the way in which I handle your personal information, you can contact me via my contacts page, phone on 07902032413 or email (if you’ve been provided this).
Complaints
If you have a complaint about how I handle your personal data please do not hesitate to get in touch. 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 ico.org.uk/make-a-complaint.
Changes to privacy notice
This privacy notice may be updated from time to time, so please check occasionally for any updates.