Privacy Policy

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. 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 keep 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.
• 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 my email (caroline@carolinedaveycounselling.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.

I am registered with the Information Commissioner’s Office [Insert registration number]. 

My phone number is: 07830 342502. My email address is: caroline@carolinedaveycounselling.com.

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: 

When you contact me with an enquiry about my counselling services, I will collect information to help me answer your enquiry. This will include your name and contact details (email and phone). 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 30 days. If you would like me to delete this information sooner, just let me know. 

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 the agreement between us. 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, an agreement between me and you). 

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. 

Whilst you are accessing counselling. 

Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if someone is in danger. 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 on my laptop and are not shared with any third party. I will keep brief written notes of each session, these are kept anonymously in a secure folder on my laptop and will not mention you by name. 

For security reasons I do not retain text messages for more than 60 days. Likewise, any email correspondence will be deleted after 60 days if it is not important or up to  6 months after our counselling has finished. If you would like  me to retain your notes or delete your information sooner than this, please tell me. 

Third party recipients of personal data 

I do not currently share personal data with third parties, for example, if I were to contract with a supplier to carry out specific tasks. If such cases arise in the future I will carefully select which partners I work with. I will take great care to ensure that I have a contract with any third party that states what they are allowed to do with the data I share with them. I would ensure that they do not use your information in any way other than the task for which they have been contracted

Use of your data

I will not transfer your data to another country, 

I do not use automated decision-making or profiling,

Your data protection rights.

I will be as open as possible 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. You can read more about your rights at ico.org.uk/your-data-matters. If I do hold information about you I will: 

• give you a description of it and where it came from;
• tell you why I am holding its, tell you how long I will store your data and how I made this decision; 
• tell you who it could be disclosed to;
• let you have a copy of the information in an intelligible form. 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 caroline@carolinedaveycounselling.com. 

If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by writing or emailing to the contact details given above. I would welcome any suggestions for improving my data protection procedures. 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. 

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 by using encrypted devices that only I have access to. 

Visitors to my website 

When someone visits my website, I do not at present use a third party service to collect standard internet log information. I do not make, and do not allow any 3rd party 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 when you visit my website. Like most websites we use cookies to help the site work more efficiently - find out about our use of cookies. [insert link]. No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the  web host before being sent to me.