Ben Chapman Counselling and Psychotherapy General Data Protection Regulation Policy & Statement.

The General Data Protection Regulation (GDPR) is concerned with personal information that I collect, store and share.

Because I am a Therapist and a Clinical Supervisor The statement is divided into 4 sections.


Section 1: GDPR for Clients
Section 2: GDPR for Supervisees
Section 3: Erasing Your Information (applies to Clients and Supervisees)
Section 4: Your Rights (applies to Clients and Supervisees)

Section 1: GDPR for Clients

Personal Information I Collect and Store

  • Name, Age, Date of Birth, Address.
  • Telephone/SMS number (plus permission to send SMS & leave voicemail).
  • Email address.
  • Counselling & Psychiatric History, Medical conditions relevant to counselling, Prescribed medication.
  • Relationships, Family Structure, Support Networks.
  • Presenting Difficulties and Issues.
  • Brief Case Notes.

How I Store Your Personal Information

Storage Methods.

Paper: written notes (described below).

Smartphone: I will store your contact information in my contacts that backs up to my private outlook account. The Smartphone is passcode protected. This allows me to contact you in case of emergencies.

Email/SMS: your email address and correspondence will be stored in my email account (currently outlook) by nature of you contacting me. Your telephone number may be stored in my SMS or app should we exchange messages this way. Electronic correspondence will also be held by the corresponding app (Outlook, Phone’s SMS).

Website:None of your personal information is stored on my website, other than to momentarily collect & send it to my Outlook account for the purposes of our initial contact.

Analytics: My website host is 123 reg and collects patterns of website visitors. This does not identify individual visitors but shows me the number of visitors and the device used ie. mobile, desktop, laptop.

Google Analytics also shows website usage, number of visits, number of calls but does not identify individual visitors. This is restricted by their own terms and conditions.

Documents Held

Paper…

  • Intake Form.
  • GDPR Agreement.
  • Specific Consent Forms (i.e. for EMDR or Private Practice with under 16s).
  • Client Code (linking documents).
  • Documents above are stored in a locked filing cabinet.

Electronic…

  • Contact name & telephone- stored on Outlook and Smartphone.
  • Assessment Record & Brief Session Notes – stored on a password protected and encrypted Macbook and a password protected and encrypted back up disk.
  • Email/SMS- stored on Outlook and Smartphone.
How I may Process/Share your Personal Information.

Legitimate Interests

Supervision
I have supervision twice a month with a Psychoanalytic Supervisor qualified in this process. I also have specialist EMDR consultation once a month with a qualified EMDR Consultant. The consultation process is for my practice (rather than seeking instruction on working with you). In order to protect your privacy, my Supervisor/ Consultant will not know you personally nor professionally. I will refer to you by your first name, and I may refer to your information verbally when it’s helpful to my professional processes.

Therapeutic Will.
Your name and contact details will be shared with my Therapeutic Executor. This is so that you will be contacted on the event of my death, should you still be in therapy with me.

Emergencies.
If your health is in jeopardy (provided I have your consent) I may share your contact information with a GP or an emergency healthcare service (e.g. Mental Health Crisis Team).

If I have become aware of your intent to cause harm to another person/organisation (e.g. terrorism or Child Protection & Safeguarding), the law may require that I inform an authority without seeking your permission. In such a situation, the law may require that I share your personal information without your knowledge.

Legal Obligation

I may have to share information with a court of law if I am issued with a court order

I keep anonymous clinical notes of each session in line with the requirements of my professional insurance.
This is also to keep records where processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

I keep financial records for 7 years according to legal requirement.

Consent

If you have requested that I share information with another professional or professional body.

Section 2: GDPR for Supervisees

Personal Information I Collect and Store

  • Name, Age, Date of Birth, Address.
  • Telephone/SMS number (plus permission to send SMS & leave voicemail).
  • Email address.
  • Accrediting Body details.
  • Brief Supervision Notes.

How I Store Your Personal Information

Storage Methods.

Paper: written notes (described below).

Smartphone: I will store your contact information in my contacts that backs up to my private outlook account. The Smartphone is passcode protected. This allows me to contact you in case of emergencies.

Email/SMS: your email address and correspondence will be stored in my email account (currently outlook) by nature of you contacting me. Your telephone number may be stored in my SMS or app should we exchange messages this way. Electronic correspondence will also be held by the corresponding app (Outlook, Phone’s SMS).

Website: none of your personal information is stored on my website, other than to momentarily collect & send it to my Outlook account for the purposes of our initial contact.

Analytics: My website host is 123 reg and collects patterns of website visitors. This does not identify individual visitors but shows me the number of visitors and the device used ie. mobile, desktop, laptop.

Google Analytics also shows website usage, number of visits, number of calls but does not identify individual visitors. This is restricted by their own terms and conditions.

Documents Held

Paper…

  • Supervisee Information Form.
  • GDPR Agreement.
  • Documents above are stored in a locked filing cabinet.

Electronic…

  • Contact name & telephone- stored on Outlook and Smartphone.
  • Brief Supervision Notes – stored on a password protected and encrypted Macbook and a password protected and encrypted back up disk.
  • Email/SMS- stored on Outlook and Smartphone.
How I may Process/Share your Personal Information.

Legitimate Interests

Supervision

I have my work with supervisees supervised twice a month with a Psychoanalytic Supervisor qualified in this process. Your supervisee reference or name and caseload will sometimes be discussed but I will only use the references or first names for clients that we have agreed on in supervision to protect their confidentiality

This consultation is to explore processes that may be playing out within the supervisory frame and within the clinical work.

Therapeutic Will.

Your name and contact details will be shared with my Therapeutic Executor. This is so that you will be contacted on the event of my death, should you still be supervised by me.

Emergencies.

If I have become aware of your intent to cause harm to another person/organisation (e.g. terrorism or Child Protection & Safeguarding), the law may require that I inform an authority without seeking your permission. In such a situation, the law may require that I share your personal information without your knowledge.

Fitness to Practice

Although most clinical concerns can be dealt with within the supervisory frame if concerns about clinical practice are enduring and do not alter even when challenged and worked with they can sometimes become a fitness to practice issue.

In these situations, for the safety of clients and my supervisees, I may have to contact accrediting bodies to report my concerns. This a last resort and rarely happens but is one of my ethical duties as a Clinical Supervisor.

In this situation I would notify my supervisee beforehand that this was going to happen. I would then contact your accrediting body sharing appropriate information as to identify you and sharing my concerns as regards clinical practice.

Legal Obligation

I may have to share information with a court of law if I am issued with a court order

I keep anonymous clinical notes of each session in line with the requirements of my professional insurance.

This is also to keep records where processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

I keep financial records for 7 years according to legal requirement.

Consent

If you have requested that I share information with another professional or professional body.

Section 3: Erasing your Information.

If you choose not to continue working with me after your initial session your information will be disposed of 2 weeks after as confidential waste.

If you do decide to continue, when we have finished working together, I will erase electronic copies of your personal information & correspondence within one month.

I will hold onto your case notes for up to seven years past the end of our working together. For under 18’s this will be 7 years from your 18th birthday.

This is so that I have a reference of our work in situations such as you returning to work with me in the future. After this time has passed, I will delete them.

Section 4: Your Rights.

You have the following rights…

To be informed what information I hold (i.e. this document).

To see the information I hold about you, which has to be responded to within one month of the request.

To rectify any inaccurate or incomplete personal information.

To withdraw consent to me using your personal information.

To request your personal information be erased (though I can decline whilst the information is needed for my competent practice).

NB: A printed copy of this statement will be given to you when we first meet. If we agree to continue working together, we will both sign the printed copy of this statement to indicate our agreement.