GDPR POLICY

All your information is managed appropriately regarding confidentiality.  I am registered with the Information Commissioner’s Office (ICO) Registration Number ZB 343300.

Angela Naylor
Rowan Cottage
Dallas
IV36 2SA

My privacy policy adheres to the General Data Protection Regulation (GDPR) (2018).  Here I explain what information I collect, how I use it, and your rights to accessing or erasing this data.

‘I’, “me’ and ‘my’ refers to Angela Naylor,  Counsellor and Psychotherapist at AMN Counselling & Psychotherapy.  I am the Data Controller with sole responsibility for processing data collected by AMN Counselling & Psychotherapy.

‘You’ and ‘your’ refers to the Data Subject i.e. the counselling client of Angela Naylor.

1.  The information I collect, how and why:

i.  By filling in the contact form with your  data, you  authorise this application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header. Contact details are collected using Microsoft Forms: name, address, email  and telephone number, together with your preferred/acceptable contact methods, your nominated emergency contact and details of your GP surgery in case of emergency.  This is so that I can contact you between sessions if required and after your last session to request an evaluation of the service you have received from me.  I ask for emergency contact/GP details to ensure that, should the need arise, I can contact the relevant parties concerned.  These details are maintained separately from the professional notes I take to support our work – see (ii).

ii.  Professional notes: my professional notes support my work with you and may typically contain attendance dates; signed contracts; and consents; brief summaries of our sessions relevant to the work of therapy; a record of my therapeutic interventions and actions; copies of our correspondence and any information sheets I give to you; material produced, brought or utilised during a session.  I keep these notes to organise my professional thoughts; provide me with an aide-memoir for incidental details; to make changes in client material more apparent; to provide evidence of the degree of care I take in my professional practice.  

I collect this information through written notes which are not stored electronically and are kept in a secure location at my practice.  These notes use a code to preserve your client anonymity and any corresponding inventory are maintained separately from your contact details and held securely.

2.  Who I will share this information with:

Your confidentiality in our therapeutic relationship is paramount and is balanced against the need to keep you and others safe and to also abide by the UK law.

Because I am bound by UK law, and because I want you and others to be safe, under certain circumstances, for example, if I feel you are at risk of suicide, or if I believe you may be harming others, especially children, I may have to break confidentiality and share your information with other health or social care professionals or the emergency services.  Wherever possible, I will endeavour to advise you in advance that I must do this, but this may not always be possible.

There may also be situations where I could be legally required to disclose information, for example when ordered to do so by a Court of Law or by statutory obligation to disclose information to the authorities; for example, concerning knowledge of acts of terrorism, drug or people trafficking, or the neglect or abuse of a child or other vulnerable individual.  In some circumstances I may be asked by the police or solicitors to assist them in a case by releasing your client notes.  After receiving such a request, I will first seek legal advice from my professional indemnity insurance provider, and I will ensure that any information relating to third parties is removed before releasing the information.

Sometimes I may also wish to share your information in order to consult with another health professional about your wellbeing, such as your doctor.  Should this be the case I will approach you to sign a Consent to Third Party Disclosure authorisation form before doing so and involve you in the review of any records held about you, before making the disclosure.

Like other counsellors and psychotherapists, a requirement of my professional registration with COSCA includes attendance for clinical supervision on a routine basis to ensure that our practice is safe, ethical, and effective.  My supervision is undertaken by another qualified and experienced therapist who has received additional training in supervision.  The process is confidential but subject to the same rules about confidentiality as my own client work.  Every effort is made to maintain client anonymity during supervision and your name will not usually be disclosed.  My supervisor also adheres to the GDPR (2018) and I can provide you with a copy of my supervisor’s privacy policy on request.  

3.  How long I keep your information:

Notes will normally be deleted three months after your counselling sessions have ended.  You agree to inform me if notes might be needed for judicial/social services support (i.e., benefits applications, judicial proceedings, Insurance, etc) Notes will then be kept according to the requirements set by the relevant authorities.

4.  Accessing and porting your data:

At any time, you may request access to the information I hold about you.  This should be in writing, and I will respond to your request within 30 days.  There is no charge for this.  You can request and reuse your personal data for your own purposes across different services – if I receive such a request from you, I will provide it in a structured, commonly used and machine-readable form, free of charge to you.

5.  Revoking your consent:

You are entitled to withdraw your consent at any time – please ask by email or in writing.

6.  Right to erasure:

You are entitled to ask for your personal data to be deleted.  Please ask by email or in writing.  I can refuse to comply with your request to erasure: to comply with a legal obligation; for public health purposes that are in the public interest; in the exercise or defence of legal claim.

7.  Data breaches:

In the unlikely incident of a security incident affecting the confidentiality, integrity, or availability of your personal data, whether caused deliberately or accidentally, I will notify the breach to the Information Commissioner’s Office (ICO) within 72 hours and if the breach results in a risk to your freedoms and rights, and if there is a high risk, I will also report the breach to you.

8.  Your right to complain:

You have a right to complain to the ICO if you think there is a problem with the way I am handling your data.  You can call the ICO on 0303 123 1113 or visit their website at www.ico.org.uk/concerns/