My privacy statement

Scope

The General Data Protection Regulation is implemented in the UK by the Data Protection Act (2018).  

I take data protection seriously and I am committed to protecting your personal data. This Privacy Notice explains how I collect, retain and process your personal data and the rights you have in relation to it.

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Information about me

I am a professionally trained and qualified psychotherapist. I am qualified to work with individuals and couples. I am a Registered Member COSRT (College of Psychosexual and Relationship Therapists) and I am therefore bound by the Code of Ethics of this organisation.

I am registered with the Information Commissioner’s Office and my registration number is ZA145016

Your personal data

For the purposes of providing psychotherapy services, I will ask you to provide me with personal information such as your name, address, date of birth, contact details and details of your GP.

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During or after our therapy sessions, I may make notes which may include what is defined as sensitive personal date. This may include information about your gender, ethnicity, marital status, sexuality, religious or cultural beliefs and your physical and mental health.  It may also include information on any medication you receive.

This data is held securely and is not shared with anyone else except for the purposes of supervision, which is a practice requirement for all psychotherapists, and other than as set out in section 5 below.

Legal bases for processing any personal data

In terms of the legal bases I rely on to process your information, these are where the processing is necessary, or you have consented to such use:

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• For the purpose of delivering psychotherapy and psychosexual therapy;

• For my legitimate interest in managing, quality assuring and supervising these services;

• To comply with the obligations of the Code of Ethics of COSRT

Consent

Prior to therapy commencing, I will ask you to agree to this Privacy Notice. By agreeing to this Privacy Notice you are consenting to my processing your personal data for the purposes outlined. You can withdraw your consent at any time by giving me notice in writing to my email address at: jaubrey2016@gmail.com.

I will keep your personal information secure. I will not disclose your personal information, except for the purposes of supervision as referred to above or unless I am required to do so to meet my legal or regulatory obligations. For example, I have a legal obligation to disclose information under the Children Act 1998, The Children (Scotland) Act 1995, the Terrorism Act 2000, The Drug Trafficking Act 1994, The Modern Slavery Act 2015 and in connection with financial crimes. I am also required to abide by other such legislation as may from time to time come into force.   

Confidentiality may also be broken for reasons of public interest or public health.  

In addition, I may disclose confidential information if you say or imply, or I have other reason to believe, that you are at risk of causing serious harm to yourself or others; or where such disclosure is permitted by law and is required to protect my interest; or where disclosure is made at your request or with your consent.    

Retention Policy

I will process personal data for the duration of any psychotherapy sessions I provide to you. After the therapy ends, I will continue to store for seven years only the personal data needed to meet any regulatory or legal obligations.

After this period, all personal data will be deleted or destroyed, unless basic information needs to be retained by me to meet my future obligations to you, such as erasure details.  

Data storage

All data is held securely in the UK. Data is password protected. Any physical notes are held and stored securely.

Your rights as a data subject

At any point whilst I am in possession of, or processing your personal data, you have the following rights:

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• Right of access – you have a right to request a copy of the information I hold on you;

• Right of rectification – you have a right to correct data I hold about you that is inaccurate or incomplete;

• Right to be forgotten – in certain circumstances you can ask for the data I hold about you to be erased from my records;

• Rights to restriction of processing – where certain conditions apply you have the right to restrict the processing of data;

• Right of portability – you have the right to have the data I hold about you transferred to another individual or organisation.

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When the client is a couple, then the data remains the confidential material of the couple relationship and as such no one person may request access to personal data for disclosure to a third party.

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If I refuse your request under rights of access, I will provide you with a reason as to why, which you have a right to legally challenge. At your request I can confirm what information I hold about you and how it is processes.

Identification required to access personal data

I will accept the following forms of identification (ID) when information on your personal data is requested; a copy of your driving licence, passport or birth certificate, together with a utility bill no older than 3 months. All requests should be made to me at jaubrey2016@gmail.com.

Data breaches

In the unlikely event of a data breach and if the breach and if the breach is likely to result in a high risk of adversely affecting your rights and freedoms, then I will notify the ICO within 72 hours and inform you without undue delay.

Complaints

If you wish to make a complaint about how I am processing your personal data, you can contact the ICO at http://ico.org.uk/

Consent

It is a requirement that you give your explicit consent to allow me to document and process your personal data. I will ask you to sign a copy of this document before therapy begins. Please note you can withdraw your consent at any time.