Introduction
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, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and Data (Use and Access) Act 2025 (DUAA).
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 including how to make data protection complaints.
‘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.
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).
How I use your information
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, phone number, email address, access requirements, and purpose for counselling. Alternatively 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 6 months. If you would like me to delete this information sooner, please let me know.
While you are accessing counselling.
Everything you discuss with me is confidential. That confidentiality will only be broken if I believe there to be a risk of harm to you or anyone else, or if you infer that you are involved in illegal activities. I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely in a password protected file, your mobile number will be stored in my telephone under your first name only. I will keep written notes of each session, these are kept securely in a locked filing cabinet and are anonymised so that you cannot be identified. Our appointments, identified by a unique client code, are stored in my electronic calendar.
After counselling has ended.
As a rule, your contact details will be deleted from my records, and your details removed from my smart phone, my computer, and from the file given to my professional executor. However, in rare cases I may decide to keep some text or email exchanges for longer in order to protect my professional integrity. My session notes will be kept for 3 years and will then be deleted. Any text or email exchanges that I have decided to keep, will be deleted after 3 years. In almost all cases, after 3 years I will remove all details of our work together from my files. In rare cases I may decide to keep some records for up to 7 years to protect my professional integrity, under the same security measures.
Third party recipients of personal data
My professional executor (who would be responsible for dealing with clients if I were suddenly unable to work) will be provided with a secured file containing your contact details. She, like me, is bound to keep this data safe under GDPR.
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. In the case of notes about our sessions, I may decide to show them to you only whilst we are together in a session. Requests should be made in writing. In some circumstances, I may need additional information to verify your identity or clarify the scope of your request before responding.You can read more about your rights at www.ico.org.uk/your-data-matters. 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 shellyramuducounselling@gmail.com.
Complaints procedure
If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by emailing me shellyramuducounselling@gmail.com. I will acknowledge receipt of any complaints made within 30 days of receiving them and without undue delay, take appropriate steps to respond to complaints, including making appropriate enquiries, keeping you informed and letting you know the outcome.
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 www.ico.org.uk/make-a-complaint.
You can also make a complaint to my professional body, the British Association for Counselling and Psychotherapy (www.bacp.co.uk)
Data Security
I take the security of the data I hold about you very seriously and as such I take every effort to make sure it is kept secure. I use password protected devices and a locked filing cabinet.
