Your privacy is a priority. Counselling Psychology For You, registered address Clarendon House, 52 Cornmarket Street, Oxford, OX1 3HJ, respects and complies with the EU General Data Protection Regulations (GDPR) enacted under the UK Data Protection Act 2018. This means that Counselling Psychology For You is committed to achieving the industry standards that ensure the technical, administrative and physical security of your personal information.
Dr Louise Fletcher is registered as data controller with the Information Commissioner’s Office (ICO): ZA841581.
Please find below the details of Data Protection and Privacy Consent Policy for Counselling Psychology For You. This explains how I am meeting my obligations to you under the GDPR (General Data Protection Regulation).
Who I am and what service I am providing
My name is Dr. Louise Fletcher and I am a Counselling Psychologist registered with the Health and Care Professions Council (HCPC) and Chartered by the British Psychological Society (BPS). I provide psychological therapy to clients through my independent practice and sole-trader business, Counselling Psychology For You. This policy also covers any other clients contracting with Dr. Louise Fletcher for professional psychological services. For the purposes of this policy, the term “client” covers each and all of these client groups.
Why I need your personal data
Information is collected by Dr Louise Fletcher in order to provide professional services. As a health professional, I am required to keep records of the work I do. I only collect and store information which is relevant to our therapeutic work together, and which will enhance your care. I am permitted to collect and keep this information by law.
I routinely audit the effectiveness of the service that I offer and, for this reason, retain information about the outcomes of therapy such as scores on the questionnaires I ask you to complete, or the number of therapy sessions you have.
How I will use your data within my practice
I use the data I hold about you to contact you about appointments and to take notes about what we have covered together. This ensures continuity of care and means I am able to provide you a better service.
- Appointment scheduling: initial appointments will be arranged via the email address provided when you first got in contact. Alternatively, you may book an appointment with me directly via my online diary hosted by Acuity. In order to schedule an appointment, your name, email address and contact telephone number are required. Note that neither of these methods provide encryption. I strongly recommend that prospective clients provide minimal personal information when making an initial website or email enquiry. The purpose of the initial enquiry is to arrange an appointment, where there will be a confidential space to discuss your difficulties and requirements in detail.
- Assessment Appointment: further personal information is collected during an assessment appointment. This includes your full name, address, date of birth, your nationality, whether English is your first language, your education and medical history. All clients must also provide emergency contact details. Should an emergency situation related to you, the client, arise during an appointment, I will notify your emergency contact if I judge that such notification is essential to your safety and wellbeing. The contact details of your GP and other professionals involved in your care can be noted, if you consent for them to be informed about our work together.
- Written notes are taken during assessment and therapy sessions. As a Health and Care Professions Council (HCPC) registered Counselling Psychologist, I am required to keep records of counselling psychological practice. Professional practice, therefore, requires note taking and accurate record-keeping. Such notes notes must also be held securely. Written notes are transferred to a separate cloud-based digital drive and the paper notes are shredded. Your file is allocated a random code and you can be provided with a link to these notes, if requested. There are no personal identifiers in these notes but there will be sensitive information relevant to therapy contained in them. However, notes and personal details are kept separately, in a fashion designed to avoid inadvertent disclosure.
- Clients are offered an opportunity, but are not obliged, to complete a feedback form at the end of therapy. Feedback is collected in order to improve my practice and the infrastructure around the delivery of my service to clients.
- Payment: I issue invoices using Quickbooks and accept payment via Square and Bank Transfer. Your name, email address and telephone number is used to provide a record of payment for services.
- Video calls: I use Zoom to conduct our assessment and therapy sessions. All calls are encrypted.
- Emails: our initial contact will be via my publicly advertised email address email@example.com which is hosted by Google. When we start therapy, I will set you up with a free encrypted anonymous email account with ProtonMail. From this point on, I recommend that we only communicate with me using this email as this protects your privacy. If you do not wish to use the ProtonMail account, I encourage you to be thoughtful about what is included in your email correspondence and to consider which email account you are choosing for your communication.
- Text messaging and phone calls: if you wish to use regular text messages or telephone calls to communicate with me, please note that they are not 100% securely confidential. If you choose to use them please restrict their use to making or changing appointments. I strongly advise that clients do not use text messages to communicate sensitive information. If you would like a more secure way of texting or phoning me, we can use Signal. This is similar to WhatsApp but more secure. Let me know if you would like to use this option, otherwise I will assume you are happy for me to communicate with you using your regular telephone number. Client mobile numbers may be stored in a device which is in the property of Dr. Louise Fletcher. This device is password protected. Client numbers will be saved by initials only, and will be deleted at the end of therapy.
- A third party service, Google Analytics is used to collect standard internet log information and details of visitor behaviour patterns to both the website and social media platforms. This information is processed in a way that does not identify anyone.
Information may be shared with HMRC and the Information Commissioner’s Office, should this be necessary, to fulfil statutory and regulatory requirements.
Dr. Louise Fletcher receives supervision where her counselling psychology work is discussed. All client information is anonymised and this supervision is protected by a confidentiality agreement.
Information will not be shared with any third party without your written consent. However, there are limits to confidentiality. This is in keeping with the HCPC Professional Practice Guidelines.
- In some circumstances it may not be possible to get consent from a client to share information. For example, in some emergency situations, the client may be unable to communicate or give consent because they are very unwell or unconscious.
- Dr. Louise Fletcher can also disclose confidential information without consent from the client if it is in the ‘public interest’ to do so. This might be in circumstances where disclosing the information is necessary to prevent a serious crime or serious harm to other people.
- Sometimes, Dr. Louise Fletcher may be asked for information directly under the law – for example, if a court has ordered the disclosure of the information. Dr. Louise Fletcher has a legal duty to keep to orders made by the court.
- Dr. Louise Fletcher must also take appropriate action if she has concerns about the safety or well-being of children or vulnerable adults
How you can modify the data I hold about you
I routinely share with my clients my assessment letters or reports before they are finalised. There is an opportunity to request amendments at that point. If you wish to modify other data that I hold about you, please let me know so we can discuss it further. You have the right to ensure that the information held about you is accurate and complete.
How you can access data I hold about you
You have a right to request to see the data I hold about you. Legally I am required to respond within 30 days. Please contact me if you would like to access your data. There is no charge for information access.
How you can retract consent to hold and process your records
GDPR legislation states that individuals have a right to be “forgotten” i.e. for their information to be erased. I retain your personal information and health record for eight years and thereafter they are destroyed. This is in line with UK best practice for adult health and social care records (IGA, 2016). You have a right to retract consent to hold and process your records before that time if you wish. Please let me know if you wish to do so. Counselling Psychology will comply where it is applicable.
How you can transfer your personal data
If you wish your personal information to be shared with a third party, Counselling Psychology For You will comply. However, your request must be in writing.
How you will be informed about any breaches
You have the right to be informed about any breaches. If there has been an unauthorised access to your information either online or physically, you will be notified within 72 hours.
How you can raise a complaint
Please note that the work is being undertaken in accordance with the law of England and Wales and any disputes will be subject to it. If you are concerned about the health care I have provided to you, I encourage you to speak to me immediately. If you feel I have done something harmful or unethical and you do not feel comfortable discussing it with me, please contact the Health and Care Professions Council (HCPC) at Tel: +44 (0)20 7840 9814 or on email: firstname.lastname@example.org.
If you are unhappy about how your information has been managed, I hope that you would speak with me in the first instance, so that I have an opportunity to understand and rectify what may have gone wrong.
If you are not satisfied with the response you have received, or are concerned about how Counselling Psychology For You has processed your personal data, you can complain to the Information Commissioners Office (ICO).
Managing Your Consent