This Privacy Policy is intended to clarify under the General Data Protection Regulation (GDPR) All aspects regarding the protection and protection of all data provided by you, the client to me as a Trainee Counsellor/Psychotherapist. I am regarded as both a Data Controller and Data Processor as I gather, store and process data in my work as a Counsellor/Psychotherapist.
1. Data Held
a. At our first meeting, new clients will be asked for relevant personal data including name, contact phone number, contact email address, GP and emergency contact names and phone numbers and any current medications. This data will not be shared with any other party without the client’s consent, unless there is a legal requirement or court order to do so, or where there is immediate risk of substantial harm to them or to others. This data will be held by me in a folder in a closed cabinet in my private home.
b. Personal data also includes session notes which I will maintain separately. This data will be contained in a folder in another closed cabinet in my private home. These notes will consist of a brief summary of some of the points or experiences that occur in a session, and they will be pseudonymised so they cannot be linked to the identity of any person, including the client, members of their family, significant others, etc. The pairing for the individual codes and client names will be kept separately from these notes.
2. Purposes of Processing and Legal Basis
As a Psychotherapist I will use personal data relating to you for the purposes of:
a. providing you with counselling services.
b. where necessary contacting your GP or organising specialised support services for you (subject to your explicit consent, save where there is a serious concern for your safety or the safety of others); and c. to comply with my legal and regulatory obligations.
The legal basis on which I collect, process and transfer your information in the manner described above are:
a. a legitimate interest in providing you with counselling services. I will not process your personal data for these purposes if to do so would constitute an unwarranted interference with your own interests, rights and freedoms; and
b. that this is necessary for compliance with a legal or regulatory obligation that applies to Trainee Counsellors and Psychotherapists; and
c. in limited circumstances, where you have given your consent to such processing. The legal basis on which I collect, process and transfer special categories of data relating to you in the manner described above are: a. issues of public safety e.g. child protection issues or any other areas in which Counsellors are legally bound to disclose information. b. that this is necessary for the provision of health or medical care; and b. that you have given your explicit consent to such processing.
3. Data Retention
All personal data will be held by me for a period of 7 years from the date of cessation, in line with professional guidelines of the Irish Association of Humanistic & Integrative Psychotherapy (IAHIP). They will then be fully erased. Data will be held for longer if necessary, eg. in the case of an ongoing or pending court case of complaint.
4. Access to Personal Data
Clients have the right to access their data records via s Subject Access Request (SAR). This access will be arranged within 30 days. Clients may request the updating or correction of data held. Clients may request the return, copy or deletion of their data. This is subject to legal requirements that I must hold data for a minimum of 7 years. Clients may also request that their data is sent to another data controller in suitable electronic format.
5. Data Breaches
I will notify any affected party of any serious breach of any identifiable data. This would include incidents such as theft, loss, fire, or unauthorized access by another person. The Data Protection Commission will be notified of a serious breach of data.
6. Client Consent
All clients will be asked to sign to consent to my holding of relevant personal data as part of our contract of working together. This signed agreement will be scanned and held by me in a password protected filing system on my personal laptop. The original will be returned to the client for their own information/safe keeping.
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