I take your privacy and the confidentiality of our work seriously. This Privacy Notice explains what personal information I collect, why I need it, how I look after it and your rights in relation to your information.
I am the data controller for the personal information I hold about you.
You can contact me about your personal information or this Privacy Notice using the email address or telephone number you normally use to contact me.
When you enquire about counselling or coaching, and while we are working together, I may collect and hold information including:
Some of the information shared during counselling may be considered sensitive or special category personal data under data protection law, including information relating to your physical or mental health.
I only collect information that is relevant to providing my professional services and operating my practice safely and appropriately.
I use your personal information in order to:
Data protection law requires me to have a lawful reason for using your personal information.
While you are considering working with me or receiving counselling or coaching from me, I generally process your information because it is necessary in connection with the service and agreement between us.
After our work has ended, I have a legitimate professional and business interest in retaining appropriate records for the period required for professional and insurance purposes.
Some information may also need to be processed or retained in order to meet legal obligations, including financial and tax requirements.
Where I process sensitive or special category information, I do so only where there is an appropriate legal basis for doing so, including where necessary for the provision of counselling services or for the establishment, exercise or defence of legal claims.
I take reasonable steps to protect your information from unauthorised access, loss or disclosure.
I currently keep:
I aim to keep identifying information to the minimum reasonably necessary.
My electronic counselling notes are stored locally rather than in cloud storage.
My phone and computer are password protected.
Email and text messaging may be used for appointments, administrative matters and other communication between us.
Email and text messaging cannot be guaranteed to be completely secure. I therefore encourage clients to avoid sending highly sensitive information by email or text where this can reasonably be discussed within a session instead.
I do not intend routine emails and text messages to form a permanent separate counselling record.
Where a communication contains information that is important to our therapeutic work or my professional responsibilities, I may make an appropriate record of it within your counselling notes.
Routine messages and correspondence will be deleted when they are no longer reasonably required.
I use Zoom to provide online counselling sessions.
Zoom processes some technical and account information in order to provide its service.
I do not routinely record counselling sessions. I would never make an audio or video recording of a session without discussing this with you and obtaining your agreement beforehand.
Payments are normally made by bank transfer.
As a result, my bank will hold information relating to transactions between us, such as your name, account information associated with the transfer and the amount paid.
I may also retain appropriate financial records where required for accounting and tax purposes.
Our therapeutic work is confidential, but confidentiality is not absolute.
As part of safe and ethical practice, I receive regular clinical supervision and may discuss aspects of my client work with my supervisor.
Wherever reasonably possible, I protect your identity and use only the information necessary for effective supervision.
There may also be exceptional circumstances in which I need to share information without your consent. These may include:
Wherever possible and appropriate, I will discuss this with you before sharing information.
I will only share information that is necessary for the particular purpose.
If you provide an emergency contact, I will only use their details in exceptional circumstances where I have serious concerns about your immediate safety or wellbeing and it is appropriate to do so.
Wherever possible and appropriate, I would discuss this with you before contacting them.
My professional insurance requires me to retain records relating to adult clients for a minimum period.
I normally retain counselling records for seven years after our work together ends, unless there is a professional, legal or insurance reason why they need to be retained for longer.
After the relevant retention period, paper records will be securely destroyed and electronic records securely deleted.
Financial records may be retained separately for the period required by tax and accounting legislation.
Balens currently states that records relating to adult clients should be retained for a minimum of seven years.
Data protection law gives you rights in relation to your personal information.
Depending on the circumstances, these may include the right to:
Some rights are not absolute. For example, I may need to retain certain counselling records where there is a professional, legal or insurance requirement to do so.
If you would like to exercise any of your data protection rights, please contact me.
If you have any concerns about the way I collect, use, store or protect your personal information, please contact me by email.
I will acknowledge any data protection complaint within 30 days, investigate it appropriately and without undue delay, keep you informed where necessary and let you know the outcome.
You also have the right to raise a concern or complaint with the Information Commissioner's Office (ICO), the UK's independent regulator for data protection.
I may update this Privacy Notice from time to time to reflect changes in my practice, professional guidance or legal requirements.
If I make a significant change that affects how I use your information, I will let you know.
Anna Fletcher
Humanistic & Integrative Counsellor and Personal Coach
BACP Registered Member No. 407194