SEPAC Pathway privacy policy statement.
Your privacy is very important to me and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to me. I adhere to current data protection legislation Including the General Data Protection Regulation (EU 2016/679) (the GDPR), the Data Protection Act 2018 and electronic communications (EC directive) regulations 2003.
This privacy notice tells you what I will do with your personal information from initial point of contact through to after your therapy has ended including:
why I am able to process your information and what purpose I'm processing it for
whether you have to provide it to me
how long I store it for
whether there are other recipients of your personal information
Whether I intend to transfer it to another country
whether I do automated decision-making or profiling
your data protection rights.
Data controller
This term is used to describe the person/organisation that collects, stores and has responsibility for people’s personal data and in this case the data controller is Clarence Firstborn. I am registered with the information commissioner’s office. Registration number ZA770471.
My lawful basis for holding and using your personal information.
The GDPR states that I must have a lawful basis for processing your personal data, there are different lawful basis depending on the stage at which I'm processing your data which are outlined below:
if you have had therapy with me and it has now ended, I will use your legitimate interest as my lawful basis for holding and using your personal information.
If you are currently having therapy or if you are in contact with me to consider therapy, I will process your personal data where it is necessary for the creation of our contract.
The GDPR also ensures that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for me 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 I).
How I use your information.
When you contact me with an inquiry about my counselling services, I will collect information to help me satisfy your inquiry this would include:
Name
Email address
Nature of the enquiry.
Alternatively, your GP or other third party may send me your details when making a referral.
Once an appointment has been agreed I will further request:
Geographical location.
Age at last birthday
Occupation.
Emergency contact
GP details and medical history
If you decide not to proceed, I will ensure all your personal data is deleted within 48 hours. If you would like me to delete this information sooner just let me know.
While you are accessing counselling.
Everything you discuss with me is confidential and that confidentiality will only be broken if I am legally obligated to do so or there is an imminent threat from you of harm to yourself or others. I will always try to speak to you about this first unless there are safeguarding issues that prevent this.
I will keep a record of your personal details to help the counselling service run smoothly these details are kept securely and are not shared with any third party.
I will keep written notes of each session These are kept securely in a locked cabinet.
For security reasons I do not retain text messages for more than one day.
After counselling has ended.
Once counselling has ended your records will be kept for one year from the end of our contact with each other, to allow for follow-ups, and are then security destroyed. If you want me to delete your information sooner, please tell me.
Your rights.
I try to be as open as I can in terms of giving people access to their personal information. You have a right to ask me to delete your personal information, to limit how I use your personal information, or to stop processing your personal information. You also have a right to ask for a copy of any information that I hold about you and to object to the use of your personal data in some circumstances.
If I do hold information about you I will tell you:
what it is and where it came from,
why I am holding it,
how long I will store it
You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you.
To make a request for any personal information I may hold about you please put the request in writing addressing it to: info@sepacpathway.com.
If you have any complaints about how I handle your personal data, please do not hesitate to get in touch with me by email to the contact details given above.
Data security
I take the security of the data I hold about you very seriously and as such I take every effort to make sure it is kept secure. I use encrypted email services and keep records in a locked filing cabinet.
Visitors to my website.
When someone visits my website, I use a third-party service host-Squarespace-to collect standard Internet log information and details of visitor behaviour patterns, such as the number of visitors to the various parts of the site.
This information is only processed in a way that does not identify anyone.
I do not make, nor allow Squarespace to make, any attempt to find out the identities of those visiting my website.
No user specific data is collected by me or any third party. If you complete a form on my website that data will be temporarily stored on the web host before being sent on to me. I personally do not collect nor store any data on my website, the only information processed will be the contact name you give (which can be anonymised), the email address you use to send your message to my encrypted email service.