Jeanette Ely Counselling (JEC) is registered with the Information Commissioner's Office, and as a member of the BACP I abide by the ethical code of practice of the British Association for Counselling and Psychotherapy (BACP) and the General Data Protection Act of 2018.

I need to inform you of the personal details I collect from you, if you are, or were to become a client. How I store, hold, process and destroy this information.

As a client, when you attend an initial consultation with me, we will begin by setting a working agreement that explains my commitment to client confidentiality and data protection, as well as when confidentiality may be breached. You will need to sign this agreement before we commence therapy.

Lawful basis for processing personal data:

· The client gives consent for contact information to be held in order for JEC to communicate with them between sessions.

· Session information that is held, is in the legitimate interest of the client to ensure safe, ethical monitoring and therapeutic processing of the work.

· Sharing information with a GP, or similar professional, is only done when it is in the vital interest of the client to protect their life or well-being.

· Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. All of your data protection rights may apply, except the right to object and the right to portability.

Data held:

· Name (in the case of under 18’s I will also take a parent or guardians name)

· Date of birth

· Address

· Contact number (for under 18’s I will take a parent or guardians contact number too)

· Email address

· Contact details for an emergency contact (next of kin) for use if something were to happen to you on my premises

· Contact details for your GP, for use with your permission

· Personal / medical history deemed of relevance by the client.

· Session and process notes which are identifiable only by a reference code, not by client name.

Where does the information come from:

· All information is given to JEC directly by the client, verbally or in writing.

· If the client uses an online method to contact JEC, the information would then be followed up and supplied via the telephone or in person.

How does JEC seek consent and communicate about privacy:

· Clients are provided with privacy information verbally, with key details in writing, during the initial consultation at JEC.  Written copies of this full policy are provided on request.

· Consent is requested as part of the initial assessment process.

Who does JEC share information with:

· Information is for JEC use only.

· In the event of the unplanned closure of the service the information will be shared with my clinical executors for the sole purpose of informing and supporting the client in a safe and professional manner, in line with ethical practice.

· Non-identifiable information regarding the process of the work is shared with the supervisor of Jeanette Ely.

· The GP may be informed, but only if Jeanette Ely or the supervisor are concerned for the client’s immediate well-being, or that of someone else.  Where possible, it will be discussed with the client in advance.

· With a client’s express written request, JEC may provide them with written evidence of the broad fact of their attendance for their personal use.

How does JEC seek, obtain and record content:

· Clients phone JEC directly and leave their number.

· Emails sent by clients are held on a password protected computer.

· These are deleted when the information is dealt with.

· Active client phone numbers are held in paper copy in a locked cabinet.

· Written details (on paper) are taken at the time of the first consultation.

· Changes to information are made, if a client informs JEC of changes of contact or of their GP.

· Clients are entitled to withdraw their consent to JEC holding their information at any time.

Why does JEC hold client’s data:

· For contacting a client for the purposes of our work.

· For contacting the client’s GP, with their written consent.

· To record session notes to allow for accountability and monitoring of the work by the counsellor according to ethical practice.

Where does JEC hold the information:

· Written information is kept locked in a cabinet.

· Information with identifiable details are kept locked separately from session notes.

· Written information is held for a minimum of 7 years and then destroyed by shredding.

· Phone numbers with the clients’ name and address are kept separately in a locked cabinet.

· Any relevant emails are held until the information has been recorded as identified above.  

How does JEC respond to requests for data withdrawal of consent:

· Clients are entitled to see their notes and any data kept regarding them.  The client can request in writing to see them.  JEC will then make an appointment for a client to see their notes as requested in the presence of Jeanette Ely.

· Clients are entitled to withdraw their consent to holding their data at any time, by notifying JEC in writing.  Existing clients who wish to withdraw their consent will then no longer be able to receive counselling services from JEC.

· Clients are entitled to lodge a complaint with the ICO or with the professional body, BACP, if they are not satisfied with the way their data is being used.

· A request from an outside agency will be discussed with the client where legally appropriate. JEC would only provide confirmation of a client’s attendance and then only with their written consent, unless required by law to do otherwise.

· In the event of further information being subpoenaed, JEC reserves the right to provide redacted notes to ensure only relevant and factual information is shared.

Detection of Data Breaches:

· A data breach could occur in the event of the hacking of JEC’s email system or a forcible break-in to the locked records.

· In the unlikely event of a data breach happening, JEC will inform all affected client’s immediately.

How to complain:

If you have any concerns about my use of your personal information, you can make a data protection complaint via email to: info@jeanetteely-counselling.co.uk

If you remain unhappy with how I have used your data after raising a complaint with me, you can also complain to the ICO. The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint