Privacy Policy

I make every effort to comply with the UK GDPR (General Data Protection Regulation) and I pay an annual data protection fee to the ICO (Information Commissioner’s Office).

Purpose and lawful basis for processing

I keep records of personal and some sensitive data (collected during therapy sessions), for the purpose of providing a psychological therapy service to you. The lawful basis I rely on to process your personal data is article 6(1)(b) of the UK GDPR, which allows me to process personal data when this is necessary to fulfil my contract with you. In addition to the above, I sometimes use videos of therapy sessions to train other therapists. However, I would only do this with your consent, and in this case my lawful basis for processing your data is article 6(1)(a), which allows me to process personal data with your consent.

What data I need

The data I will hold about you is as follows: – Your name, address, email address and telephone number. Under UK GDPR this is classed as personal data. – Name and address of your GP and mental health practitioner (if applicable). – Brief notes on our therapy sessions. Some of this data may be classed as sensitive under UK GDPR. – Data from questionnaires aiming to evaluate the extent to which the therapy is benefiting you. – Videos of your therapy sessions, if you consent to having your therapy sessions video recorded.

Why I need it

I collect and store your personal data so that I can contact you to send written documents necessary to the therapy, to arrange appointments, or in the event that an appointment needs to be cancelled or rearranged. I keep a record of your GP and mental health practitioner (if you have one) in case I ever need to share information with them, for example if I am concerned about any safety or risk issues. I make and store brief notes on our therapy sessions as an aide memoire, to help me reflect on the therapy and deliver the best service I can to you. I keep records of data from questionnaires aiming to track your progress, to help us evaluate how effective the therapy is proving for you. We can then look at these data periodically together to help us think about any changes we might need to make. These data will also help me evaluate my effectiveness as a therapist more generally. It is possible that I might wish to analyse these data along with those from other therapies for research purposes, and if I were to publish such analyses they would be anonymous. If you consent to have your therapy sessions videoed, I will often do this in order to help me look again at what happened during the session, to help me reflect on the therapy and deliver the best therapy I can.

What I do with it

I keep your personal data in a password protected document on an internal hard drive on a laptop computer, access to which is also password protected. Therapy session notes are identified by a numerical code and kept in paper form in a locked filing cabinet with a combination lock. Data from questionnaires are transferred into a spreadsheet within 24 hours and identified by a numerical code. The paper questionnaires are shredded within 24 hours. I store videos of therapy sessions on an encrypted external hard drive that is PIN protected. I may share some videos with a clinical supervisor to gain another perspective and to help me think about what is happening in the therapy – again to help me deliver the best therapy I can. In a few cases I might wish to use a video for the purposes of training other psychologists, and you can consent to this or not, separately from consenting to have your therapy sessions videoed for the primary purposes described above. I treat your personal information and any information you share during the course of therapy as private and confidential. I would share this information with a third party only in one of the following circumstances: – For the purposes of clinical supervision, with another HCPC registered psychologist, which is a requirement of my professional registration. For this purpose I would only share information necessary to the supervision, and for the most part this would be anonymous. – If I am concerned for your safety, or you disclose information that leads me to believe that someone else may be at risk of serious harm, I may share information with another health care professional, such as your GP or mental health practitioner, or other appropriate services. In these circumstances I would share only the minimum information necessary, and I would normally discuss this with you first. – In rare circumstances I would be legally obliged to share information to third parties without telling you. Where it is necessary for me to send any communications with you or third parties by email, I use an encrypted service (Gmail).

How long I keep it

Under Common Law, I keep personal data and minimal therapy notes for six years after the end of therapy, to protect myself in the event of a claim of breach of contract or liability. After six years I will delete this data. I keep data from questionnaires in an identifiable format for six years. After this period the data will be fully anonymised. I only keep videos of therapy sessions until they have fulfilled their purpose (for my reflection, supervision, or training as described above), after which they will be deleted.

What are your rights?

Under data protection law, you have rights I need to make you aware of. The rights available to you depend on my reason for processing your information. For a full description of your rights, please visit the website https://ico.org.uk/your-data-matters/.

Your right of access You have the right to ask me for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information I process. Your right to rectification You have the right to ask me to rectify information you think is inaccurate. You also have the right to ask me to complete information you think is incomplete. This right always applies. Your right to erasure You have the right to ask me to erase your personal information in certain circumstances. However, this would not apply to your personal information and my brief therapy notes, which I need to keep for the reasons explained above (under ‘How long I keep it’). Your right to restriction of processing You have the right to ask me to restrict the processing of your information in certain circumstances. For example, if you have previously given your consent for me to use your therapy videos for training purposes, you can withdraw this consent. If I receive a request from you exercising your data protection rights, I have one calendar month to respond to you.