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 provided 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 the Privacy 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:
I am registered with the Information Commissioner’s Office as a ‘Data controller’, a term used to describe the person that collects and stores and has responsibility for people’s personal data.
I am happy to chat through any questions you might have about my data protection policy and you can contact me via my website: www.nigellack.com phone: 07941 334924 or email: hellonigel@protonmail.com
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 bases depending on the stage at which I am processing your data. I have explained these below:
If you have had therapy with me and it has now ended, I will use legitimate interest (need to process personal data in order to carry out tasks related to my professional activities) 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 performance of our contract.
The GDPR also makes sure 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/psychotherapy) and necessary for a contract with a health professional (in this case, a contract between you and I).
How I use your information
Initial contact
When you contact me with an enquiry about my professional services I will collect information to help me satisfy your enquiry. This will include contact details, reason for contacting me, psychological history, lifestyle questions, GP contact details.
Alternatively, your GP or other health professional may send me your details when making a referral, or a parent, or trusted individual may give me your details when making an enquiry on your behalf.
If you decide not to proceed, I will ensure all your personal data is deleted within fourteen days. If you would like me to delete this information sooner, just let me know.
While you are accessing counselling/psychotherapy
Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if you reveal a threat of harm, or there is a threat of harm to yourself or to others, if you reveal knowledge of terrorist activity or if a court order is received and a legal obligation arises. 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 professional services run smoothly. These details are kept securely on my password protected devices: phone, computer and are not shared with any third party.
I will keep written notes of each session; these are anonymous and kept securely on a separate password protected hard drive, secured when not in use.
For security reasons I do not retain text messages for more than fourteen days. If there is relevant information contained in a text message, I will transfer the information to your anonymised record with my notes. Likewise, any email correspondence will be deleted after fourteen days if it is not important. If necessary I will transfer the information to your anonymised record with my notes.
After counselling/psychotherapy has ended
Once counselling/psychotherapy has ended your records will be kept for five years from the end of our contact with each other and are then securely destroyed. If you want me to delete your information sooner than this, please tell me.
Third party recipients of personal data
I may sometimes share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks such as sending out invoices. In such cases I will carefully select which partners I work with. I will take great care to ensure that I have a contract with the third party that states what they are allowed to do with the data I share with them. I ensure that they do not use your information in any way other than the task for which they have been contracted.
Your rights
I try to be as open as I can be 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. You can read more about your rights at ico.org.uk/your-data-matters.
If I do hold information about you I will:
You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you. Please put any request in writing addressing it to hellonigel@protonmail.com
If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me in writing to the contact details given above. I would welcome any suggestions for improving my data protection procedures.
If you want to make a formal complaint about the way I have processed your personal information you can contact the ICO, which is the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint.
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. Using password protected devices, encrypted email & videoconference software, keeping notes on a separate password protected hard drive (secured when not in use).
Visitors to my website
Like most websites mine uses cookies or similar tracking technologies to help the site work more efficiently - This means information that the website’s server transfers to your computer. This information can be used to track your session on my website. Cookies may also be used to customize the website content for you as an individual. If you are using one of the common Internet web browsers, you can set up your browser to either let you know when you receive a cookie or to deny cookie access to your computer.
No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.
I may modify this privacy policy at any time to reflect any improvements in my data processing, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If I make material changes to this policy, I will notify you that it has been updated, so that you are aware of what information I collect, how I use it, and under what circumstances, if any, I use and/or disclose it.