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Privacy Policy

Simon Dowling Therapy is committed to protecting the privacy and security of your personal information.

 

This privacy notice describes how I collect and use personal information about you during and after your working relationship with myself, in accordance with the General Data Protection Regulation(GDPR).

 

This applies to all Clients.

 

I will comply with data protection law. This says that the personal information I hold about you must be:

 

1. Used lawfully, fairly and in a transparent way.

2. Collected only for valid purposes that I have clearly explained to you and not used in any way that    is incompatible with those purposes.

3. Relevant to the purposes I have told you about and limited only to those purposes.

4. Accurate and kept up to date.

5. Kept only as long as necessary for the purposes I have told you about.

6. Kept securely

The Kind of Information I Hold About You
 

I will collect, store and use the following categories of personal information about you; 

 

  • Personal contact details such as name, title, address, telephone numbers and personal emails addresses

  • Date of birth

  • Next of kin

  • Gender 

  • GP contact details 

  • Notes of therapy sessions 

 

I require the categories of information in the list above to allow me to perform my contract with you and to enable me to comply with my legal obligations, insurance obligations and in line with the BACP Ethical Framework.

How I Will Use Your Information

I will only use your personal information when the law allows me to. Most commonly, I will use your personal information to contact you, your GP or for a request for access to personal data from yourself or your representative. The circumstances include;

 

1. Where I need to perform the contract I have entered into with you. 

2. Where I need to comply with a legal obligation.

3. Where it is necessary for my legitimate interests (or those of a third party). 

 

I may also use your personal information in the following situations, which are likely to be rare:

1. Where I need to protect your interests (or someone else's interests).

2. Where it is needed in the public interest [or for official purposes].

 

Your contact details alone maybe shared in exceptional circumstances with a supervisor/counsellor if I should become incapacitated so that they can explain the situation to you. 

If You Do Not Provide the Information

If you fail to provide certain information requested, I may not be able to perform the contract I have entered with you, or I may be prevented from complying with my legal obligations, insurance or BACP Ethical Framework.

Change of Purpose

I will only use your personal information for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If I need to use your personal information for an unrelated purpose, I will notify you and will explain the legal basis which allows me to do so.

 

Please note that I may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data Sharing
 

I may have to share your data with third parties. I require third parties to respect the security of your data and to treat it in accordance with the law. 

Why Might I Share Your Information with Third Parties

I will share your personal information with third parties where required by law.

Data Securities

I have put in place measures to protect the security of your information. Your information is kept on an encrypted removable hard drive. I have a backup of this data which is also encrypted on a separate removeable hard drive.  

 

Any texts or emails between us will be kept for the same duration as your Counselling notes. My mobile phone is a smart phone and is password protected. The emails are also on a computer/ phone which is also password protected.

 

Third parties will only process your personal information on my instructions and where they have agreed to treat the information confidentially and to keep it secure.

 

If there is any suspected data security breach I will notify you and any applicable regulator of a suspected breach where I am legally required to do.

Data Retention

I will only retain your personal information for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any contractual, legal, accounting, insurance or reporting requirements. To determine the appropriate retention period for personal data, I consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.

Rights of Access, Correction, Erasure and Restriction

Your duty to inform me of changes

It is important that the personal information I hold about you is accurate and current. Please keep me informed if your personal information changes during our working relationship.

 

Your rights in connection with personal information

 

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information I hold about you and to check that I am lawfully processing it.

  • Request correction of the personal information that I hold about you. This enables you to have any incomplete or inaccurate information I hold about you corrected.

  • Request erasure of your personal information. This enables you to ask me to delete or remove personal information where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal information where you have exercised your right to object to processing (see below).

  • Object to processing of your personal information where I am relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where I am processing your personal information for direct marketing purposes.

  • Request the restriction of processing of your personal information. This enables you to ask me to suspend the processing of personal information about you, for example if you want me to establish its accuracy or the reason for processing it.

  • Request the transfer of your personal information to another party.

  • If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that I transfer a copy of your personal information to another party, please contact myself in writing.

If you have any questions about this privacy notice or how I handle your personal information, please contact myself: simondowlingtherapy@outlook.com. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

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