Privacy Notice for Andy Wareham
This Privacy Notice was last reviewed in October 2021.
The purpose of this privacy notice is designed to notify you of how you can expect me, Andy Wareham, to use your personal data when you enter into a counselling relationship with me.
You can find the general privacy notice for counselling@unit12 on www.cau12.com/privacy-notice.
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This privacy notice has been written in a way that I hope is clear and easy to understand. However, in order to keep it concise I might refer to terms or situations which are not immediately obvious to you. If you come across anything that you would like to have explained, please do contact me by emailing silverseascounselling@gmail.com and I will do my best to provide further clarification.
As a counsellor I highly value your right to privacy. As such, I will only use the personal data that you entrust me with for the purpose which it was given to me. I adhere to the current UK data protection legislation, including the Data Protection Act 2018, General Data Protection Regulation (EU/2016/679 - GDPR) and Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR).I am registered with the Information Commissioner's Office (ICO) under the number: ZB176784
This privacy notice covers the following points:
What personal data I collect
The purposes of processing your personal data
The legal basis for processing your personal data
How I store your personal data
Who I share your personal data with and why
How long your personal data is retained
Your rights around the use of your personal data
How to contact the authority if you have concerns
What personal details do I collect?
The details collected at the time of your initial contact with counselling@unit12 will be used throughout the counselling relationship to communicate with you in relation to appointments. As a reminder, these details include:
Your name
The name and age of a child or young person you are applying on behalf of
Your preferred contact information, i.e. your email address or a telephone number
The reason that you are seeking counselling
When you begin your counselling with me, I will collect additional personal data as part of my registration process and to ensure that the arrangement and work together can be carried out. This information includes:
Details relating to your general physical health, e.g. level of fitness, amount of alcohol you consume on a weekly basis
Details relating to your current emotional state
Details regarding your sexual orientation, preferred gender pronoun *
Details regarding your nationality *
Age(s) of and relationship of significant others, e.g. parents, siblings, children, partner *
Please note, some of the above personal data (marked with an asterisk (*)) is collected on an optional basis, as it is not essential to carry out the counselling work but can be helpful within it.
You will also be required to sign a Working Agreement (contract) for the type of counselling appointment you undertake, which will also contain
Your signature
Your address
The name, address and contact telephone number of your GP surgery
The name, contact telephone number or email and relationship to you of an emergency contact
Once the counselling work has begun, a record of your sessions will also be kept, in addition to the above mentioned personal data. This means that I will record brief notes after your sessions, to help the counselling work run smoothly and serve to aid memory about the work, as is standard professional practice. These notes are available to you to view at any time upon request and are anonymised as much as practically possible to protect your privacy.
(Additional information regarding supervision can be found in the section “Who I share your personal data with and why”.)
The purposes of processing your personal data
As might reasonably be expected, the Data Protection Act 2018 and UK GDPR both state that personal data can only be collected and used if there is a legal reason for doing so.
The below table will hopefully help show you which legal condition I am relying upon when using your personal data.
| What data |
What it is used for |
Legal condition | Legitimate Interests |
|---|---|---|---|
| Name and/or contact details | Communications - e.g. booking appointments, facilitating video call counselling sessions etc. | Performance of contract | N/A |
| Issuing invoices for payment | Performance of contract | N/A | |
| Execution of counsellor’s professional will | Explicit consent | N/A | |
| Emergency contact name and/or contact details | Communication should an emergency with you arise during a counselling appointment | Legitimate Interest | To aid in meeting our safeguarding requirements. |
| Health information, e.g. details relating to current emotional state | Session notes |
Performance of contract | N/A |
| Details relating to sexual orientation and nationality | Provision of counselling service | Legitimate Interest | To aid in the counselling work, so the performance of the contract. |
| Details of significant others |
Provision of counselling service | Legitimate Interest | To aid in the counselling work, so the performance of the contract. |
| Name and/or contact details of other therapists | Referrals | Explicit Consent | N/A |
How I store your personal data
How I store your personal data depends on the type of record that I hold the personal data on.
Paper records, such as signed working agreements or session notes will be stored in secured filing cabinets contained in my home.
Electronic records, such as your contact details, are stored on my personal laptop. As far as is reasonably practical, the device and system I use has been carefully selected on the grounds of the security they enforce. They are set up with unique username and strong password combinations and the laptop is only used by me.
Who I share your personal data with and why
Confidentiality is at the heart of all I do as a counsellor. As such, I do my best to ensure that your personal data is kept safe and secure. However, there are instances when your personal data may need to be shared with third parties. Below is a list of third parties that you can expect your personal data to be shared with, and in what situation.
Please note, where links have been included we cannot accept responsibility for the content contained within their web pages.
| Recipient of data | Reason for sharing data | Type of data shared |
|---|---|---|
| Video call software |
I use Google Meet for all my remote counselling sessions. It is a secure and encrypted service and is free for you to access. You can find the privacy and security details for Google meet here. |
Your name as you enter it when you join the meeting. |
| Room booking calendar for counselling@unit12 |
To manage the availability of the counselling room at the location we use Skedda. Please note, no personal data will not be added to any booking made in Skedda. You can find Skedda’s privacy notice here. |
|
| Counselling supervisors | Under the BACP Ethical Framework I am required to attend regular sessions with a trained Supervisor. During supervision sessions, your privacy and confidentiality will be protected by only referring to you by your first name. Any other details relating to your therapy will be anonymised as much as possible. |
First name only – to protect your privacy. |
| General details relating to your therapy sessions. |
||
| Specific details relating to your therapy sessions should an emergency or issue relating to your safety arise. |
||
| Emergency services |
In the event that an emergency took place during a counselling session, or if a safeguarding issue was raised, I might be required to contact one of the emergency services and provide them with your personal data. Please note, where possible, I will always seek to get your consent prior to contacting the emergency services. |
Name and contact details – to help the emergency services identify you. |
| Details relating to your safety or a serious crime that you have disclosed, should it be our legal requirement to do so. |
||
| GP Surgery |
In the event that, during a counselling session, I become concerned about your wellbeing or safety, I may ask for your consent to contact your GP on your behalf. |
Your name and contact information would need to be shared to help the surgery identify you. |
| Other contacts or services, e.g. parents/carers, social workers, schools, local authorities etc. |
In cases where the client is a child or young person, if they were to disclose information relating to a safeguarding concern, it may be necessary to contact their parent/carer, or if they are in care, the organisations relating to their care. Please note, depending on the concern raised, consent from the child would be sought in advance. |
Name and contact information |
| Details relating to the safeguarding concern that has been disclosed. |
||
| Other therapists | Should I not be able to provide the help needed, I may ask for your consent to refer your contact information to another therapist. |
Name and contact information. |
| General information relating to the reason you are seeking counselling. |
||
| Executors of a will and related service providers |
In the unforeseen event of the death or incapacity to work of your counsellor, your personal data will be handled by the executor of their will, in order to inform you. |
Name and contact information. |
How long I retain your personal data
The length of time your personal data will be retained for depends very much on the type or personal data it is and the reason that it is collected and used.
Your personal data will be held for the lengths of time outlined below:
| What data |
Retention period |
|---|---|
| Personal data relating to working agreement, including name, contact information, emergency contact information, GP surgery contact information, health data. |
Until the end of the counselling relationship. |
| Personal data relating to working agreement, including name, contact information, health data. |
For up to 7 years to meet the requirements stipulated by my counselling insurance company, Holistic Insurance Services, with the details of children and/or young people being held for 7 years after they turn 18. |
| All personal data relating to financial records, including name, contact information. |
Until the end of the 5th financial year after the end of the counselling relationship as required by Her Majesty's Revenue and Customs (HMRC). |
Your rights relating to your personal data
Your personal data belongs to you. As a client you entrust your personal data to me, so that I can provide you with the therapeutic help that you are seeking, but you retain certain rights over your data and how it is used.
Below are a list of your rights and how you can exercise them.
The right to be informed
In a nutshell, this is your right to know how and why your data is being collected and used by me. I hope that this Privacy Notice provides you with that information. Should anything be unclear though, please do not hesitate to contact me by email at silverseascounselling@gmail.com.
The right of access
You have a right to know what data I hold on you. As the controller of your data, I am required to respond to any request that you make to see the data we hold within 30 days of you making such a request. This is commonly referred to as a Data Subject Access Request. If you would like to see the data I hold on you, please either email silverseascounselling@gmail.com or speak to me if you have already started your counselling work with me.
Please note, while it may sound contradictory, to properly protect your privacy, I may be required to request additional personal data to verify your identity before providing the personal data to you if you email me with a data subject access request. This is in an effort to stop other people claiming to be you from getting access to your personal data.
The right to rectification
You have the right to ensure that any personal data that you have provided me with is correct. As such, if your circumstances change, for example you get a new contact telephone number, or wish to change your preferred method of contact from telephone to email, please do provide me with the up-to-date information and I will correct my records immediately.
Please note, there may be circumstances when we are not required to follow up on you exercising your right for rectification. Full details about this right can be found here.
The right to erasure
This right allows you to ask me to delete the personal data I hold on you. However, there are certain instances when I would not be able to honour your request, including those where I am under legal obligations to retain the data, for instance the HMRC requirement for my financial records to be held for 5 financial years.
Also, please note, while you are actively engaged with the counselling work, I would not be able to delete the personal data that I hold on you, as this is required by me to fulfil my side of the working agreement.
The right to restrict processing
Related to your right to erasure, you have a right to restrict how I use the personal data that you have provided me with. This right is closely linked to your right to erasure, and also has some restrictions as to when it can be exercised.
If you would like more information about this right, you can find some here.
The right to data portability
Should you wish to move from using me to another therapist, you have the right to request that I make the personal data I hold on you available in a format that is easily accessible and machine-readable. Specifically, this right applies to data I hold electronically.
Should you wish to exercise this right, please do contact me via email at silverseascounselling@gmail.com.
The right to object
Another right that is similar to both the ‘right to erasure’ and the ‘right to restrict processing’ is your right to ask me to stop using your data at any time.
This again does only apply in certain circumstances, so please do contact me at silverseascounselling@gmail.com to discuss exercising this right. Also, you can find additional information here.
Rights in relation to automated decision making and profiling
I do not profile you or make any automated decisions regarding you in any way. As such, while this is a right you have, it does not apply to the service I provide.
How to contact the authority if you have concerns
If you have any concerns around the use of your personal data, I would prefer it if you would address these with me first. You can either contact me by email at silverseascousnelling@gmail.com or, if you are a current client, you can speak to me directly.
However, if you do not feel that I provide you with a satisfactory response, you are also entitled to lodge a complaint with the Information Commissioner’s Office (ICO), which is the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals.
You can contact the ICO via their website: https://ico.org.uk