Information Commissioners Office (ICO) registration reference: ZB277953
Data controller and processor: Elaine Collins
Data subjects: Clients, Trainees, Supervisees
This policy is written with the intention of providing transparent information regarding how Elaine Collins Integrative Therapy control and process personal data. To find out more about General Data Protection Regulations (GDPR) and your rights, please go to https://ico.org.uk/for-the-public/ or https://ico.org.uk/global/contact-us/
The service
Elaine Collins provides personal therapy and supervision by private contract to clients, trainees and supervisees. In many instances, the Therapy Agreement (See Therapy Agreement Document) is between therapist and client. Some agreements involve a third party, for example, where parents have brought their child to counselling and fund the counselling, or where a third party such as training institutes, charity, human resources or private company request and fund therapy for an employee or student.
Data collection points
Enquiries to Elaine Collins Integrative Therapy are received via a number of channels: in person, telephone, text or email. Initial enquiries usually contain some personal information such as names, emails and telephone numbers. Emails are received via linked profiles from professional directories and websites which opens an email in your own browser/system or direct contact independent of these methods. Other data is collected at initial meetings and following each therapy session.
Data collection and processing, what information and why do I process it?
Any client data collected and/or retained by Elaine Collins Integrative Therapy (including personal information) is solely processed in order to make relevant contact with and provide counselling and training services to clients.
Personal information collected/processed:
Full name
Date of birth
Home address
Telephone number
GP name and address
Emergency Contact/Parent/Carer Name and telephone number and/or email address (where relevant)
Email address
Other information collected/processed regarding clients/attendees
Brief session notes made in anonymised form, identifiable only by unique client codes.
Anonymised monitoring information, identifiable by unique client codes
Text messages
Emails
Feedback Forms
Data storage, retention and disposal
Elaine Collins Integrative Therapy store paper records, including personal information, in a locked filing cabinet and electronic information in password protected and encrypted format (including email, telephone numbers and text). Telephone numbers and anonymised, with those and any text messages being held on password protected professional mobile phones. Session notes are held separately from personal and identifying information in anonymised format. Data is held for a maximum of 7 years after client’s last contact with Elaine Collins Integrative Therapy, in line with insurance requirements and GDPR. After this time, data is then disposed of securely and confidentially.
Data sharing
It is rare that any personal information would be shared. As an NCIP registered therapist, anonymised client information is shared with professional supervisors (a requirement of registration) in order to maximise service provision to clients. Personal information will not be shared with any other party without prior client consent, with the exception where Elaine Collins Integrative Therapy believe that not sharing the information would result in the risk of harm to clients or any other person or if there is a legal requirement to do so.
These circumstances include:
Safeguarding concerns relating to the client or a vulnerable party:
If you disclose involvement in drug trafficking, money laundering, or contemplated or actual acts of terrorism.
Other evidence of a serious crime.
In the event that Elaine Collins is in some way incapacitated, all records will be destroyed confidentially by Elaine’s supervisor. Every effort will be made to ensure current clients are informed of this action.
Therapy agreements
All clients proceeding with therapeutic service are required to consent in writing to both the parameters of therapy counselling and data collection within a detailed counselling agreement. This agreement sets out elements of the therapy contract with a detailed privacy statement prior to a section where personal data is collected.
Where another type of third party is involved, unless we gather personal information pertaining to themselves, they will not be required to provide their consent. Any information shared regarding the client (other than attendance information) will be subject to client providing consent.
Access to personal data and requests to erase, limit use or amend personal data
As clients consent to and provide personal information, they are informed that they can request access this information at any time and provided with details as to where they can learn more about their rights in relation to GDPR. No charges will be made for accessing personal information and the personal information will be provided at the earliest possible time. Clients also have the right to request that data is erased, limited or amended and the right to be compensated for any harm caused by incorrectly processing personal information.
Data breeches
Where there has been a breech to Elaine Collins Integrative Therapy’s GDPR policy, for example data has been shared with a third party without consent or data has not been destroyed in a timely manner, the breech will be reported to the ICO within 72 hours of being discovered.
This policy is written with the intention of providing transparent information regarding how Elaine Collins Integrative Therapy controls and process personal data. If you have any queries regarding this policy, please contact us using the details above. To find out more about General Data Protection Regulations (GDPR) and your rights, please go to https://ico.org.uk/for-the-public/ or https://ico.org.uk/global/contact-us/
