· I have a responsibility to protect its client’s personal information, and by adhering to the principles set out by the General Data Protection Regulation (GDPR) May 2018, clients have improved control over how their information is collected, stored, shared and used.
· By providing your information as a client with me you are giving your consent for your information to be held and used as written in this privacy statement, but you can withdraw your consent at any time. My clients have right to access information held about them, and this includes case notes written by me. You have the right to have your information corrected or erased, to restrict how your information is used, and reclaim your personal data. There is usually no charge to process your request and I will meet your request within one month
· I recognise that confidentiality is of the utmost importance to clients and therefore, essential to the effective running of the service.
· I adhere to the Ethical Framework of The British Association for Counselling and Psychotherapy (BACP). A client is defined as anyone approaching me with a view to entering a counselling relationship with me.
· I am registered with the Information Commissioners Office (Reference: A8882832, Organisation name: Reflect Ltd).
1. This Confidentiality Policy is based on the principle that the client’s interests, rights and wishes are of fundamental importance. My clients have the right to be confident that:
o Personal information will be collected such as name, address, contact phone numbers, email address, bank details, date of birth and GP details. Sensitive information will be collected at assessment and during each session.
o Information given by the client will only be used for the purpose which it was disclosed and will not be disclosed to a third party without the express consent of the client.
o Information given may be used for counsellor development, research and monitoring the Service and will be anonymised in all cases.
o I create a code/pseudonym for each client to support confidentiality, so that case notes and measuring tools (e.g. CORE forms) cannot be immediately matched to a client.
o I write a brief case note about the client’s weekly session, which will include the main themes and content of the session. This can be useful when the progress of a client is being reviewed and may of help if a client chooses to return to counselling.
o Client information including case notes are stored electronically using cloud storage secured with a minimum of two passwords. Any paper forms signed by the client will be scanned in and the original either stored in a locked cabinet or destroyed. Information will be held for 6 years after the contact with the client ends and destroyed after that period.
o I also hold contact details to communicate with a client by email and phone. This is also held in secure cloud storage and accessed via my mobile and other electronic devices. These are password and/or fingerprint protected.
2. Process for data breaches
· A request to access data can be made verbally face to face or in writing.
· A request for copy of the information not the originals could be made available.
· Data processors have written contract with controller.
3. Information received by me from a client will be treated as confidential to me. If I receive a request to disclose information to a third party, then full and informed consent of the client will be sought. The client has the right to withhold consent, either about a specific piece of information or specific agency or, more generally, if consent is withheld, any information will not be shared with a third party, except in exceptional circumstances (see 4. bullet 2 below).
o In some cases, clients will provide me with information in the expectation that this information will be shared out by me, e.g. in the form of a referral. Nevertheless, it will still be made clear to the client what information will be passed on, and who will receive it.
4. Limits of Confidentiality.
o Information about my clients is confidential to me.
o There are exceptions to the requirements to maintain confidentiality. These are: -
a) If I believe that a client to be at serious risk of causing significant harm to him/herself or to others.
b) Where there is a suspicion that the client may be abusing a child and causing significant harm. (Impairment of child’s health or development, physical, intellectual, social, emotional, behavioural);
c) Where there is a suspicion that an act of terrorism, drug dealing, money laundering or female genital mutilation may be committed.
5. Sharing of Information
o There is an expectation that only in exceptional circumstances will information be shared between me and other agencies involved in the client’s care. This will be done sensitively and purposefully and with the client’s permission except in exceptional circumstances.
Signed: Steve Wright Date: 4/12/21