Privacy Policy
Counselling with Tom is committed to complying with the terms of the UK General Data Protection Regulation (UK-GDPR), the Data Protection Act 2018 and to the responsible and secure use of your data. Counselling with Tom has a legitimate interest in processing personal data to provide counselling services. The purpose of this policy is to let you know what personal information I collect and hold, why I collect this data and how it used, how long it is stored for and your rights over your personal data.
- Information about you held
- The use of this information
- Security
- Data Retention
- Your rights over your personal data
- Complaints Process
Contact Details
Email: hello@counsellingwithtom.com
Telephone: 07824 153683
Information Commissioner's Office (ICO) Registration: ZB398762
Information about you held
I collect personal information from you when you enquire about my counselling services, this may be to answer your enquiries, to keep you informed and to set up an initial consultation. This information includes taking basic personal details such as name, address, date of birth, contact information, information about the nature of your enquiry and your GP’s details. Alternatively, your GP or another health professional may send your details when making a referral. If you decide not to proceed with services through Counselling with Tom, I will ensure all your personal data is deleted within 1 month. If you would like your information deleted sooner, please email hello@counsellingwithtom.com.
If you are undertaking counselling sessions, I will process your personal data where it’s necessary for our contract together. This will firstly include at the beginning, creating and keeping record of your personal details such as name, address, date of birth, contact & emergency contact information, information about the nature of your counselling, personal history, and your GP’s details. It may also include sensitive personal information, which can include information about a persons’ health, race, ethnicity, sexual orientation, gender and religion. The lawful basis for 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 you and Counselling with Tom). I will also keep confidential anonymised brief session notes on a password protected computer. Any personally identifiable information is separately stored in a locked filing cabinet. No cookies are used for www.counsellingwithtom.com.
The use of this information
Your data will be used only to provide you with my services and to give you information relating to my services. Your information will never be sold or shared with another organisation so that they contact you for marketing activities. Your information will not be sold regarding web browsing activities. I will not share your details with any other person or organisation without your knowledge and permission unless there is a requirement to do so as stated in the counselling contract (separate document). For example, I have a legal requirement to break confidentiality if information is disclosed about involvement in or knowledge of an act of terrorism, money laundering or drug trafficking, upon request to release notes upon court order from a judge, or to report concerns of harm or abuse to a minor or vulnerable adult. There may also me a requirement to breach confidentiality if there is a concern about a risk of serious harm to yourself or someone else. This may involve sharing information with third parties such as the safeguarding board, CAMHS, CMHT, Emergency services, Multi Agency Safeguarding Hub and/or GPs. Full details of the limits to confidentiality are contained in the counselling contract (separate document).
Security
Counselling with Tom ensures the security of any personal information held by using secure data storage technologies and precise procedures in how personal information is stored, accessed and managed, and will take all reasonable precautions to prevent the loss, misuse or alteration of information you give me.
Counselling with Tom may communicate via email, text message or telephone to make arrangements for sessions. I use a separate mobile phone which is password protected; however, text messages are not a fully secure means of communication. Email, unless encrypted, is not a fully secure means of communication. Email communication will be sent from a secure email provider (Hushmail), and not encrypted unless requested or stated otherwise, for example client contracts will be sent via encrypted email, and if you chose to make contact via the ‘Get in Touch’ webform on www.counsellingwithtom.com, this sends an encrypted email to my account.
Counselling with Tom may provide online video counselling sessions through a secure, encrypted online meeting room via Zoom. In this case, you’ll be sent a link to an encrypted meeting, with your client reference number as the meeting name. As such the session is anonymised and any information held in calendars will be retained electronically but will not hold any personally identifiable details, to protect confidentiality. Counselling with Tom may provide telephone counselling sessions via a regular telephone call, using a separate mobile phone which is password protected. I will also keep confidential anonymised brief session notes on a password protected computer. Any personally identifiable information, such as your name or address, is separately stored in a locked filing cabinet.
Whilst I endeavour to keep my systems and communications protected against viruses and other harmful effects, and although I have taken measures to use secure service providers with encryption potential, there is a possibility, although minimal, that confidentiality could be compromised when using 3rd party platforms, such as Zoom, Hushmail and telephone network providers, and Counselling with Tom cannot bear responsibility for the confidentiality and protection of these communication providers.
Data Retention
If you decide not to proceed and start with services through Counselling with Tom, I will ensure all your personal data is deleted within 1 month. In general, messages via email or text will be deleted within 1 month, unless Counselling with Tom has a legitimate reason to retain any information. Once your sessions have come to an end, Counselling with Tom has a legitimate interest for holding and using your personal information, such as for insurance provider and ethical body requirements. Once sessions have ended the following data retention will apply:
Emails – deleted within 1 month
Text messages – deleted within 1 month
Notes and records – deleted/destroyed after 5 years from the date of your last attended session.
Your rights over your personal data
Under the UK GDPR you have a number of rights in respect of personal information held about you as follows:
Right to be informed
Individuals have the right to be informed about the collection and use of their personal data.
Right of access
Individuals have the right to access and receive a copy of their personal data, and other supplementary information. To make a request for any personal information held about you, please put the request in writing to hello@counsellingwithtom.com.
Right to rectification
The UK GDPR includes a right for individuals to have inaccurate personal data rectified, or completed if it is incomplete. If you feel any information is held incorrectly and would like something amended, please contact me at hello@counsellingwithtom.com.
Right to erasure
The UK GDPR introduces a right for individuals to have personal data erased, however there are exceptions to this. If you wish your information to be erased, please put the request in writing to hello@counsellingwithtom.com.
Right to restrict processing
Individuals have the right to request the restriction or suppression of their personal data.
Right to data portability
The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services.
Right to object
The UK GDPR gives individuals the right to object to the processing of their personal data in certain circumstances.
Rights related to automated decision-making including profiling
The UK GDPR has provisions on:
automated individual decision-making (making a decision solely by automated means without any human involvement); and profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process.
You can read more about your rights at ico.org.uk. If you wish to exercise any of these rights or find out more, please email hello@counsellingwithtom.com.
Complaints process
If you have any complaint about how your personal data is handled, please do not hesitate to get in touch at hello@counsellingwithtom.com. If you wish to make a formal complaint about the way your personal information is processed, you can contact the Information Commissioner’s Office (ICO) which is the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint.