CLARITY Talking Therapy Privacy Policy
Version: 1.0
Created by: Gordon Howe AMACCPH., BSc., PGDip., APT Acc., RNMH.
Verified by: Kirsten Ferguson BSc., PGDip., RNMH.
Date: 25/03/2024
THIS NOTICE DESCRIBES HOW PRIVATE INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN OBTAIN ACCESS TO THIS INFORMATION.
PLEASE REVIEW IT CAREFULLY.
To provide you with the best service possible, we will hold your (MINIMAL AND NECESSARY) personal contact details and records of your therapy sessions. Please find below important information about how this information will be held and used. We understand how important your privacy is. We take care to maintain your confidentiality in accordance with current data protection laws (GDPR, 2018) and the ethical guidelines of regulatory bodies including our accreditation authority the ACCPH (Accredited Counsellors, Coaches, Psychotherapists, Hypnotherapists) These guidelines have been set up to protect your confidential material and ensure that your therapist always conducts themselves with professionalism and ethically with integrity.
Your personal information.
Our devices are all password protected, with strong passwords that are all different from each other, and which we change at suitable intervals. We do not share our devices or passwords with anyone else not associated with The Clarity Talking Therapies.
We do not have any personally identifying information of our clients on a mobile phone (security coded), except for your number and names, our minimal paper information (session notes) are coded and shredded when no further legal need for them arises).
We do not record phone calls, Skype, Facetime, Teams or Zoom sessions. If you wish to record a session for personal use only, to help you remember, you're welcome to do so, you need to acknowledge this to your therapist beforehand and that data is then your legal responsibility. (These are all end to end encrypted by each individual service provider)
We do not keep your personal or sensitive information stored on any external hard drive or memory stick. While our work is active, we keep electronic information in the following two places only:
1. On our password protected HP Desk top computer. (Online privacy statement | HP® United Kingdomhttps://www.hp.com › gb-en › privacy › privacy)
2. Our password protected Outlook account (CLARITYTHERAPY@outlook.com) (please see Micro Soft / Outlook GDPR compliant security measures https://learn.microsoft.com/enus/compliance/regulatory/gdpr
We use Google Drive to collect and store your personal data. At the point of booking your initial consultation with us, you will be asked for your personal contact information, for example your name, address, email address and telephone number and you may also choose to share details of the issues you are looking for help with.
In order to be able to fulfil our legal duty of care to you, in your initial consultation or first treatment session, your therapist will ask you for contact information for your GP and elected Emergency Contact person. These details will be recorded securely in paper form and will only be accessible to The Clarity Talking Therapy.
Please note that we will need to keep a record of your name and client reference number for seven years after the end of your therapy, so that we can respond effectively to any potential legal requests regarding your clinical notes and treatment. We will never pass on your contact details to any third-party organisations for the purposes of sales, marketing or research and will never use your personal data for any purposes other than the administration of the counselling service we are providing to you i.e. to arrange, cancel and rearrange appointments and collect payment for sessions.
Online Bookings
When you make an online booking or payment, this will either be through the business WhatsApp, business email, The Clarity Therapy Clinic website, although we do recommend BACS Bank Transfer.
Anonymised payment details are recorded in our financial income reports. These reports will only hold your initials. The HMRC requires that we retain this information for 5 years after the end of the financial year.
Cookies
Like many websites, we use cookies. A cookie is a small amount of data that is sent to your computer or mobile phone browser from a website’s computer and is stored on your device’s hard drive.
Cookies record information about your online preferences. They help us understand how visitors engage with our site so that we can improve your online experience with us. We do not use cookies to collect personally identifiable information about you. Each website you visit can send its own cookie to your browser if your browser’s preferences allow it. To protect your privacy, your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites.
How to control and delete cookies
You may restrict or block the cookies which are set by our website, or any other website, through your browser settings. You can also ask your browser to alert you when a cookie is issued.
For more information about cookies and how to manage them is available at www.aboutcookies.org
We use Google Analytics to understand how visitors engage with our website. It collects information anonymously and reports website trends without identifying individual visitors, this is a normal practice with all websites.
Your therapy sessions
Everything that you discuss with your therapist is strictly confidential. Confidentiality will only be broken if there is concern about your safety or the safety of someone else or if we are instructed to do so by a Court of Law. We will always endeavour to speak to you about this first.
During remote working your therapist will ensure that they are conducting online and telephone sessions in a quiet, private and confidential setting. We have selected video calling platforms that offer end to end encryption to ensure maximum privacy. Please note however that we cannot be held responsible for any breaches that occur due to failures in this technology. Your therapists clinical work is discussed with a professional supervisor. This is to ensure that they are offering you the best service possible. These conversations are bound by confidentiality, and you will only be referred to as (e.g. Client 1).
Your therapist will also keep minimal paper notes of each session, these are stored in a securely locked cabinet. These notes are for our therapist’s use only and help to keep a track of everything that is being discussed while in ongoing therapy sessions. In line with industry guidelines, Minimal notes will be kept securely for seven years after your therapy comes to an end, this is a Legal requirement. After this time, they will be confidentially securely shredded and destroyed via a registered Government approved waste centre.
Who we may need to share your information with Third parties.
There may be occasions when we need to share personal or sensitive information about you with third parties, specifically, your insurance company or other health professionals involved in your care (see below). When we do so, we will comply with all aspects of the GDBR (2018) and consult and gain your permission via email.
Your insurance company
If you are claiming the cost of your sessions through your insurance company, your insurance company may request details of your treatment and progress from us to authorise further funding for your treatment. We will share the minimum amount of information necessary with your insurance company and notify you of their request of information.
Specialist healthcare providers
If there is a specialist healthcare provider or other professional involved in your care, your treatment with us or them could be negatively impacted if they did not know you were working with us, we will consider this very carefully. We will always ask you for your consent before sharing any personal or sensitive information when liaising with other health professionals who may be involved in your care.
We will also check with you what information you do and do not wish for us to share. We only share sensitive information that would be of direct importance to your healthcare i.e. directly relevant to you getting the most appropriate treatment for your needs.
General Practitioners (your GP)
It is not typically necessary for us to contact a client's General Practitioner, unless we have concerns about the medication or treatment that a general practitioner may be prescribing you, or if your GP is the gateway to enable you to access other healthcare that you need. We will only do this with your request via email.
If we share any information with your GP, it will be in written form (email), in explicit consultation and collaboration with you, with the purpose of you getting better quality health care. We would ensure you have the opportunity to edit before it is sent and that you have a copy of the final draft.
Responding to family members and concerned others
Occasionally we get enquiries from our client’s family members or partners making initial enquiries that is, sensitive information about their loved ones because they want to help. In these circumstances, if we have not had explicit written consent about information sharing from our client themselves, our policy is to not respond to such enquiries to ensure that we safeguard, rather than accidentally breach privacy rights, or compromise trust with our client. This also applies to you (our client), if you are concerned about a loved one, and what they are thinking or feeling about your therapy progress. We recommend that you are comfortable, willing, and as transparent as you feel necessary as you deem appropriate in sharing your therapy details out of concern for them. concern for them, you can ask them to contact us directly if you wish, please send a request to us to do so by email with their details and what you wish us to discuss.
Data Usage
We will only use your email address and telephone number to contact you about your appointments. Your therapist may also contact you directly via email to share information with you that is pertinent to your therapeutic process. Your phone number may also be used to issue appointment reminders via text message. You can opt in or out of text updates by letting us know via email.
Your rights
Any personal data retained by our service is kept in accordance with the GDPR, 2018.
Under these guidelines you have the following rights
The right to request access to your data
You can request to view the information that we hold about you (contact details, appointment logs etc.) at any time. If during therapy you would like to see your session notes, please make this request to your therapist directly. Should you require a copy of your notes after your therapy has come to an end you can make this request by emailing CLARITYTHERAPY@outlook.com
The right of rectification
At any point during your time using our service or during the seven years thereafter, while we retain your records, you have the right to request amendments to your contact details or session notes. This right can be exercised by contacting us by email.
The right to be forgotten
You can request that we delete and confidentially destroy the information that we hold about you and your sessions at any time. This request can be made by contacting us at CLARITYTHERAPY@outlook.com
Instances where we would not be able to comply with your request are as follows:
1. It is necessary for us to retain these records in order to continue providing an effective service.
2. We are compelled to retain these records by a Court of Law
3.We require these records in order to establish, exercise or defend legal claims.
We make every effort to ensure that our clients' personal information is held securely and to safeguard against unauthorised access, whether we receive it via our website, emails, text, over Zoom, Microsoft Teams or phone or in person. At the same time, in agreeing to our privacy policy:
1.You acknowledge that the privacy of your communications and personal information can never be completely guaranteed when it is being transmitted over the internet.
2. You acknowledge and agree that you share information via the internet at your own risk.
3. You agree to take responsibility for your own role in safeguarding your data privacy in the email address, or txt message you choose to use and whether or not you choose to password protect information you send to us.
Our website's contact form
If you get in touch via our contact form on our website, you've got options to choose what information you wish to share with us. Your contact form goes directly through to us via secure end to end encrypted email.
Consent
When you book your first session with us you will be asked to sign our policies and procedure information pack to confirm that you consent to the storage and processing of your personal data for the purposes of providing therapeutic services.
You are entitled to withdraw this consent at any time and can do so by emailing our office at: CLARITYTHERAPY@outlook.com
Breaches of data protection
In the event of any breach of our data protection policies, we will notify you and the Information Commissioner’s Office (ICO) within 72 hours and will seek to rectify this immediately.
Raising concerns
Should you have any concerns about our data protection practices, you can raise these directly with your therapist. If you believe that your rights under the GDPR regulation have been infringed, or that the processing of personal data relating to you does not comply with lawful regulation, visit the Information Commissioners Office to find out how such matters can be dealt with on your behalf. Their helpline is 0303 123 1113.
