Supplementary Privacy Notice Information

Legal Basis

As might reasonably be expected, the Data Protection Act 2018 and 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

Third Parties

Below is a list of third parties that you can expect your personal data to be shared with, and in what situation.

Recipient of data Reason for sharing data Type of data shared
Email provider In order to be able to communicate with you. Whatever personal data you include in an email; including information such name and contact information and, in the case of the initial enquiry, details regarding the reason that you are seeking counselling.
Customer Relationship Management System In order to store your contact information securely, should it be needed. - Name and contact information.
- Emergency Contact information.
- GP surgery contact information.
- Client health data.
Accountancy services To ensure the management of our financial accounts, we use accountancy software to issue invoices and track payments.
Additionally, should you pay your counselling fees by bank transfer, please not that your name will be visible to the bank and our accountants.		 Name and contact information.
Website provider To enable you to submit an enquiry to see one of the therapists who use our service. Name, contact information and reason for seeking counselling if supplied using the website’s Contact Form.
Video call software To facilitate online counselling sessions where necessary or requested by you. Name
Counselling supervisors Under the BACP Ethical Framework our counsellors are 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, we might be required to contact one of the emergency services and provide them with your personal data.
Please note, where possible, we 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, your counsellor was concerned about your wellbeing or safety, they 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 counselling@unit12 not be able to provide the help needed, we 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.

Length of Data Retention

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 with counselling@unit12, should you proceed with the counselling work, 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. Up to 12 months after the end of our therapeutic working relationship.
Please note, should information regarding a safeguarding issue be divulged during the therapeutic process, the retention period will be extended to beyond the above mentioned 12 months for adult clients, is the client is classed a vulnerable adult, or for 7 years after a young person leaves school.
All personal data relating to financial records, including name, contact information. Legally we are required by His Majesty's Revenue and Customs (HMRC) to retain financial data until the end of the 5th financial year after the end of the counselling relationship.
However, many financial systems, including the one I use, stores this information for longer than the required 5 years.
Referral list of other therapists displayed on the counselling@unit12 website, including name and contact information. Until such a time as the therapist withdraws consent for their details to be displayed in this manner.

You are also entitled to lodge any 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