In line with the General Data Protection Regulations 2018 (GDPR), I am registered as a ‘data controller’ with the Information Commisioner’s Office (ICO) and I am required to tell you what data I am collecting from you as a client and what I intend to do with it.

Details about Third Party/Internet/Website privacy policy are provided below.  

This privacy policy is subject to regular review and modification in line with the prevailing legislation at the time.  You are therefore advised to review it on a regular basis.  Any modifications or clarifications will be effective immediately upon posting on this website.

Data Kept and Why it is Needed

Registration Form 
Paper document including the following information:
• Name/date of birth/age: basic information which helps me get to know you.
• Contact details: home address, email address, phone number: this information is used to make contact with you regarding your sessions and to establish your preferred method of contact. 
• GP details:  this information and/or details of other relevant professionals working with you is needed by me should there be a situation in which I am concerned you are at risk so for your safety may need to make contact with your GP.  Except for in an emergency I will aim to discuss this with you beforehand and obtain your consent.
• Medical information: this is limited to any relevant medical information needed to assist counselling for example to enable me to meet any access requirements, current medication as it may impact our work and any medical diagnoses which may be relevant to an emergency whilst in session.

Counselling Agreement
This is a paper document which sets out how we will work together and is signed by you the client to indicate your consent to this agreement.

Counselling Session Notes 
These are securely stored in locked filing cabinets under a Unique ID Code.  Notes are brief and factual and taken to assist provision of effective counselling within the Ethical Framework of the British Association of Counselling and Psychotherapy (BACP); for supervision purposes and in line with insurance requirements.  These notes may contain sensitive personal data.

Unique ID Codes
These are held on paper and the purpose is to anonymise your notes.  This information is kept separate to your notes and contact details and is securely held in a locked filing cabinet.  

Privacy Policy Agreement Form 
This is a paper document outlining the Privacy Policy and signed by you the client to give consent to the collection and storage of information as described within this document for insurance purposes and under the rules of the ICO and GDPR.

Email and Phone Details 
These may be stored on my mobile phone (which is password protected) so I may contact you regarding sessions for the duration of our work together.  Likewise email information may be stored on my laptop for the duration of our work together.  My laptop is password protected and has anti-virus software protection.

Relevant Information
Any relevant information from our email or text message exchanges are recorded onto your paper Counselling Session Notes.

Sharing of Data
In rare circumstances it may become necessary for me to share your data with a third party if: 
• Required by law, for example, relating to terrorism, anti-money laundering, drug trafficking or to comply with a court order;
• I believe that you the client, or someone else, is at risk of significant harm or abuse, including child protection issues.  In such a situation, the law may require that I share your personal information without your knowledge. However, at any other time I would seek your initial consent first.
• I have appointed a Clinical Executor. In the unfortunate event I can no longer work with you due to illness or other unforeseen events they will have access to your details and will get in touch with you.

Data Storage
Data held on paper is stored in secure locked filing cabinets.  Paper records with personal identifiable information are held separate from documents identified by your Unique ID Code.  

Your phone number/email details may be kept in my business mobile phone and email application (phone and/or laptop), which are passcode protected.

Data Retention and Disposal
Your paper data: registration form, counselling agreement, privacy policy agreement form, counselling session notes and Unique ID Code (held separately) are kept for 5 years after counselling has ended in line with the requirements of my insurance company.  Client contact details are held securely for 1 year.  After this time, they will be confidentially destroyed.

I will delete your phone number/email from of my mobile phone/computer 1 month after counselling finishes.

All text messages/email communication exchanges will be deleted as soon as they are no longer needed and at least within 1 month of us finishing working together.  However, the phone may keep a record for some time thereafter.
 

Your Rights
Under GDPR you are entitled to the:

Right to be Informed
Which is the purpose of this privacy notice.

Right to Access and Update Records
You have the right to ask for a copy of your personal information, free of charge for the initial request and to receive this within 30 days from request. You also have the right to ask me to amend or change any incorrect information about you.

Right to be Forgotten and Restrict Processing
You have the right to ask me to erase any personal information I hold about you, including personal information that is no longer relevant for the original purposes – for example when our work together has ended or if you wish to withdraw consent. Please note that it is not an absolute right to be forgotten if I am legally obliged to keep any records requested by my insurance company.

Data Portability
You have the right to receive your personal information as previously provided, and to transfer this information to another party.

Right to object
You have a right to withdraw consent from me.

Please contact Alison Pritchard, the data controller for alp counselling via email if you would like to exercise your rights listed above.

If you are not happy with the way I use your data you can complain to the ICO or call 0303 123 1113.

Consent
If you do not consent to me using your data in this way, it is unlikely that I will be able to work with you for legal reasons.

Third Party Apps & Internet Privacy Notice

In using the Internet for communications, GDPR (data protection) requires me to tell you what happens to your information in more detail when using an Internet service from a third party. Below are the services I currently use which you may access.

General Enquiries (non-clients)
Enquires that are made via any of these services and do not result in you becoming a client (or someone that you have enquired on behalf of), will not be stored like client data above (see Privacy Notice).  Any communications will be deleted within 30 days and removed from trash.

Deleting Browser History and Cookies
You may not want anyone who has access to your computer/other device to know you are looking for a counselling service and it may be particularly important for your safety to know how to erase your Internet search history and cookies from any websites you have visited whilst looking for a counsellor. Information can be found on the Internet on how to do this depending on the device you are using.  Please note I am not liable for any potential issues this may cause to any of your devices should you follow instructions from a third party website.

Email
If you as a client contact me via email, any necessary correspondence information may be recorded onto your session notes. My email -  alison@alpcounselling.com is provided by ionos; their privacy policy can be found here https://www.ionos.co.uk/terms-gtc/privacy-policy/ The section ‘Email and Office’ provides the relevant information.

WhatsApp
If you as a client contact me via WhatsApp regarding sessions, any necessary correspondence information may be recorded onto your paper Counselling Session Notes.  Your contact details for WhatsApp may be stored on my mobile phone (which is password protected) whilst we are working together but will be deleted within 1 month of ending counselling.  The privacy policy for WhatsApp is provided and you agree to this and their terms of use when you create an account for their service.

Website
This website is hosted on the ionos.co.uk platform which provides the online platform allowing me to advertise my services to you. Your data may be stored through ionos.co.uk’s data storage, databases and the general ionos.co.uk applications.

My website uses cookies which records non identifiable information on visitors to my website to track and this information is used for my own purposes. My cookie policy will appear when you visit my website and disappear once accepted. 

Social Media
I have profiles on Instagram and Facebook which are used for advertising purposes.  I do not knowingly communicate with clients via these applications. Their privacy policies are available through their individual websites and you agree to these and their terms of use when creating an account with their services. 

Zoom
For online counselling I utilise the Zoom platform.  Details of Zoom’s privacy policy can be found here https://explore.zoom.us/en/privacy/.  All meetings held on Zoom are given a unique meeting number and password for each client.