Introduc5on

Serenity Counselling Privacy PolicyYour privacy is very important to me and you can be conﬁdent that your personal
informa8on will be kept safe and secure and will only be used for the purpose it was given tome.
I adhere to current data protec8on legisla8on, including the General Data Protec8on
Regula8on (EU/2016/679) (the GDPR), the Data Protec8on Act 2018, and the Privacy andElectronic Communica8ons (EC Direc8ve) Regula8ons 2003.
This privacy no8ce tells you what I will do with your personal informa8on from the ini8al
point of contact through to aRer your therapy has ended, including:• Why I am able to process your informa8on and what purpose I am processing it for• Whether you have to provide it to me• How long I store it for• Whether there are other recipients of your personal informa8on• Whether I intend to transfer it to another country• Whether I do automated decision-making or proﬁling, and• Your data protec8on rights.
‘Data controller’ is the term used to describe the person/organisa8on that collects andstores and has responsibility for people’s personal data. In this instance, the data controller
is me.
I am registered with the Informa8on Commissioner’s Oﬃce, Registra8on Number:ZA406350.
I am happy to talk through any ques8ons you might have about my data protec8on policy
and you can contact me via email Admin@SerenityCounselling1.co.uk. For further
informa8on about this policy or any aspect of our data protec8on, please contact me:
My postal address is: 92 Causeway End Road, Lisburn, BT28 2ED
My email address is: Admin@SerenityCounselling1.co.uk
My telephone number is 07714399352.
My lawful basis for holding and using your personal informa5on
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:

1

•
•

•

If you have had therapy with me and it has now ended, I will use legi8mate interestas my lawful basis for holding and using your personal informa8on. Your signed
contractual agreement will conﬁrm understanding of the Privacy Policy.
If you are currently having therapy or if you are in contact with me to consider
therapy, I will hold and process your personal data as it is necessary for theperformance of the service oﬀered, (in this case counselling) and necessary for acontract with a health professional (in this case, a contract between you and me).
GDPR also requires me to ensure that I look aRer any sensi8ve personal informa8onthat you may disclose to me appropriately. This type of informa8on is called ‘special
category personal informa2on’. This data is collected when needed to ensure thatyou receive a safe and professional service. The lawful basis for me processing any
special categories of personal informa8on is by consent to provide an appropriate
treatment plan. E.g. Psychometric ques8onnaires.

How I use your informa5on
Ini5al contact
When you contact me with an enquiry about my counselling services I will collectinforma8on to help me sa8sfy your enquiry. This will include such details as name, address,
date of birth, presen8ng issues, next of kin, emergency contact details and will be clear on
the assessment form. This will include physical, emo8onal welfare and relevant historic
informa8on which will assist me in your counselling process.
Alterna8vely, your GP or other health professional may send me your details when making areferral, or a parent or trusted individual may give me your details when making an
enquiry on your behalf.
If the client is a child or young person (aged 16 or under) the person with parental
responsibility may complete the assessment form in consulta8on with the client and provide
the informa8on required. A parental responsibility contract and consent form will be signedby the same person, including parental consent for the retaining and storing of the child or
young person’s data in accordance with this policy.
If you decide not to proceed I will ensure all your personal data is deleted or shredded
within two weeks from the 8me you inform me you do not want to proceed. Where I haveknowledge of a safeguarding issue, or legal ac8on or a concern I reserve the right to holdthe record un8l that reason no longer exists.
While you are accessing counselling
Be assured that everything you discuss with me is conﬁden8al.
That conﬁden8ality will only be broken if there is risk to yourself or others- or you disclose
something to me which has poten8al for risk or requires monitoring – clearly stated on the2agreement signed at the outset. I will always speak to you about this ﬁrst unless you cannot
be contacted e.g. a child in session and an immediate concern or a vulnerable person.
I will keep a record of your personal details to help the counselling services run smoothly.
These details are kept securely and encrypted digitally on OneDrive or in paper form in alocked cabinet and are not shared with any third party. Clinical supervision is part of anecessary requirement to prac8ce but cases are brought anonymously. The session notes
are coded. The building is alarm controlled and serviced regularly and evidenced by
cer8ﬁca8on.
I will keep wrijen notes of each session, these are kept for 5 years and are stored in a lockedcabinet in a locked room. Online communica8on is two factor protected. For security
reasons I ensure my telephone is security updated, password protected and password
changed regularly. Whatsppp is encrypted. Video sessions are conducted using VSee whichis encrypted – they are not digitally recorded.
If there is relevant informa8on contained in a text or encrypted whatsapp message I will
ensure that this informa8on is not shared and the work telephone safely monitored at all
8mes. No other party will have access to this except the secretary of the Prac8ce.
Likewise, any email correspondence is held securely on one drive with two factor security.
A@er counselling has ended
Once counselling has ended all your records will be kept for 5 years from the end of ourcontact with each other, in keeping with professional insurance requirements andprofessional guidelines. Paper records are then securely destroyed. Digital records aredeleted permanently. Where I have knowledge of a safeguarding issue or legal ac8on, I
reserve the right to hold the record un8l that reason no longer exists.
Third party recipients of personal data – referrals – eg Agencies or Insurance Companies
I some8mes share personal data with third par8es, for example, where I have contractedwith a referrer to carry out speciﬁc tasks. In such cases I have carefully selected which
partners I work with. I request that the third party is compliant with data protec8on
requirements.
Your Rights
I try to be as open as I can be in terms of giving people access to their personal informa8on.
You have a right to ask me to limit how I use your personal informa8on, or to stop
processing your personal informa8on. You also have a right to ask for a copy of any
informa8on that I hold about you, by way of subject access request. In the interests of best
prac8ce, counselling may have to end if processing is requested to be restricted.
3If you ajended as a couple or as family where others have shared personal informa8on in
the sessions, then consent MUST be granted from the other par8es before copies of
informa8on is shared.
You also have the right to ask me to delete your personal informa8on. I reserve the right toreject any such request which would be declined because of the relevancy of this work.
There is also a requirement to retain client records in order to fulﬁl professional insurance
and professional indemnity. The informa8on is not erased in the interests of the client’swelfare. If consent is requested to be withdrawn counselling will not con8nue as the service
cannot be provided eﬀec8vely. This is explained under the right for the provider to not erase
informa8on.
You can read more about your rights at hjps://ico.org.uk/for-the-public/
If I do hold informa8on about you I will:• give you a descrip8on of it and where it came from;• tell you why I am holding it, tell you how long I will store your data
• tell you who it could be disclosed to;• share with you a copy of the informa8on if requested.
You can also ask me at any 8me to correct any genuine mistakes there may be in thepersonal informa8on I hold about you. The ra8onale is discussed transparently and both
par8es must be in agreement.
To make a request for any personal informa8on I may hold about you, please put the request
in wri8ng, addressing it to Admin@SerenityCounselling1.co.uk A period of no8ce – 4 weeks
is required for this request to be fulﬁlled.
If you have any complaint about how I handle your personal data please do not hesitate to
get in touch with me ﬁrstly by wri8ng or emailing to the contact details given above andhopefully this can be resolved at local level.
However, if this is not resolved and you want to make a formal complaint about the way I
have processed your personal informa8on you can contact the ICO which is the statutory
body that oversees data protec8on law in the UK. For more informa8on go to
hjps://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. I use two factor authen8ca8on, one drive and haveappropriate locked facili8es in a purpose built building.

4

Visitors to my website
My website does not oﬀer the facility for the submission of personal informa8on. The
website is hosted by 123Reg. When someone visits my website, I use Google Analy8cs tocollect standard internet log informa8on and details of visitor behaviour pajerns. I do this toﬁnd out things such as the number of visitors to the various parts of the site. This
informa8on is only processed in a way that does not iden8fy anyone. I do not make, and do
not allow Google to make, any ajempt to ﬁnd out the iden88es of those visi8ng mywebsite.
I use legi8mate interests as my lawful basis for holding and using your personal informa8on
in order to assist you fully and formulate an individual treatment plan.
I use Google Analy8cs so that I can con8nually improve my service to you, You can read
Google Analy8cs privacy no8ce here: hjps://policies.google.com/technologies/partner-sites
I use Wordpress as the content management system for our website - ﬁnd out about
Wordpress and data protec8on here: hjps://en-gb.wordpress.org/about/privacy/

5