Privacy Notice for Geanina Roman

This Privacy Notice was last reviewed in March 2025.

The purpose of this privacy notice is designed to notify you of how you can expect me 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 http://www.cau12.com/privacy-notice.

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I value your privacy and it is very important to me, and you can be assured 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.

I am registered with the Information Commissioners Office (ICO) under the number: ZB873091.

This privacy notice informs you of how I handle your personal information from initial point of contact until the end of your therapy with myself and afterwards, including:

• 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 data I collect and for what purpose

The details collected at the time of your initial contact with myself will be used throughout the counselling relationship to communicate with you in relation to appointments. As a reminder, these details include:

• Your name

• Your preferred contact information, i.e. your email address or a telephone number

• The reason that you are seeking counselling

If you decide to proceed working 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:

• Your address

• Your date of birth, ethnicity and sexual orientation

• Details relating to your general physical health, e.g. level of fitness, amount of alcohol you consume on a weekly basis, whether you take any drugs etc.

• Details relating to your current and past emotional state

You will also be required to sign a contract for the type of counselling appointment you undertake, which will also contain:

• Your signature

• The name, address and contact telephone number of your GP surgery 

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”.

If you decide not to proceed working with me, I will ensure all your personal data is deleted within one week of receipt of you confirming this. If you would like me to delete this information sooner, just let me know.

The legal basis for processing your personal data

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. 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 store your personal data

I will keep a record of your personal data, i.e. your name, address, email and telephone contact details, dates attended and brief notes to help the counselling agreement run smoothly and serve to aid memory about the work, as is standard professional practice. These details are kept securely in a password protected document  during the work and for maximum of six years following ending counselling, after which they are destroyed securely. If you want me to delete your information sooner than this, please tell me.

Your GP details are held so that they may contacted in the event that you are considered to be at risk.

Third party recipients of personal data

Your personal contact data is used for initial contact and arranging sessions. 

While you are accessing counselling, rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if the law requires me to. I will always try to speak to you about this first, unless there are safeguarding issues that prevent this. 

There are times when it may be necessary to share your name, date of birth and address in order to safeguard you or someone in your care in an emergency situation.

These are as follows: 

Your name and date of birth would be shared with your GP to identify you if they are contacted in the event that you are considered to be a risk.   

Your name and address may be shared with the emergency services in the event that you or someone in your care is at risk.

The BACP requires a commitment to working ethically, therefore as a member, I take being trustworthy as a serious ethical commitment and adhere to the BACP Ethical Framework for the Counselling Professions which requires me to undertake professional supervision with another experienced counsellor/therapist qualified in this process. This process is for my professional practice. Wherever possible, identifiable details are not shared in the supervision process. 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. Confidentiality extends to this supervision and with the same exceptions in law and to protect from harm.

Third party recipients of personal data

Sometimes your personal data may get shared with third parties, for example, where you pay by bank transfer, your details will be shown as a transaction on a statement.

How long your personal data is retained

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.

Following your initial contact, I will retain your contact information for the period of up to one (1) calendar month, to enable communication prior to your first therapy session.

Should you, at that stage, decide not to proceed with attending counselling or, should there not be availability to offer you an appointment at the time, your personal data will be deleted after the above stated calendar month has elapsed.

Should you proceed with the counselling work, your personal data will be held for the lengths of time outlined below:

Your rights around the use of your personal data

Your personal data belongs to you. As a client, you are entrusting 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 at geaninatherapy@hotmail.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 I 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 contact 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 I am not required to follow up on you exercising your right for rectification. Full details about this right can be found here: https://ico.org.uk/your-data-matters/your-right-to-get-your-data-corrected

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 were I am under a legal obligation 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 our side of the working agreement.

The right to restrict processing
Related to your right to erasure, you have a right to restricting 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: https://ico.org.uk/your-data-matters/your-right-to-limit-how-organisations-use-your-data

The right to data portability
Should you wish to move from working with 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 easily accessible and machine-readable. Specifically, this right applies to data I hold electronically.

Should you wish to exercise this right, please do let me know.

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 to discuss exercising this right. Also, you can find additional information here: https://ico.org.uk/your-data-matters/the-right-to-object-to-the-use-of-your-data

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 services 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 is you would address these with me first. You can either contact me by email at geaninatherapy@hotmail.com or, if you are a current client, you can speak to me.

However, if you do not feel that I am providing 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

My contact and registration details 

Name: Geanina Roman

You can contact me by Email: geaninatherapy@hotmail.com

I am a member of the The British Association of Counselling & Psychotherapy (BACP) 409231

Information Commissioners Office (ICO) registration number: ZB873091