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 given 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 any personal information you may give me, either as a client, a prospective client, someone who has communicated with me about my services, or as a visitor to my website.

Data Controller
‘Data controller’ is the term used to describe the person/ organisation that collects and stores and has responsibility for people’s personal data. As a sole trader, I Fran Slater am the Data Controller and am registered as such with the ICO.

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 are currently having counselling or if you are in contact with me to consider counselling, I will process your personal data where it is necessary for the performance of our contract.
● If you have had counselling with me and it has now ended, I will use legitimate interest as my lawful basis for holding and using your personal information.
● 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) and necessary for a contract with a health professional (in this case, a contract between me and you).

How Information is Collected
The personal identifiable information I collect, store and use comes entirely from our conversations, emails, texts and phone calls. The information others may hold comes from our online communication and/or from financial transactions between us.

Types of Information Held
Personally Identifiable Information I hold Your contact Information: Name, address, phone numbers, email address, occupation, age, gender, present location, employment and relationship history, health, past/present relationships.

Communication Information
From letters, emails, texts, and phone calls.

Contracts & Consents

Information about Contracts & Consent such as signed letters of consent. Information required to fulfil the counselling agreement between us. Information about financial transactions between us.

Anonymised information I hold
Information discussed during sessions and case notes.

Third Parties
Third parties may also hold information gathered through your interactions with me. This includes:
● Information derived from the use of cookies on my website. (Note 1)
● Information derived through email, SMS, phone contact between us (Note 1)
● Information derived from our use of videoconferencing applications (Note 1)
● Information about financial transactions between us, including financial accountancy services that I may engage
● Information derived from the location of our phones (Note 2)

Note 1 – this is meta-data such as date, time, IP address and duration of communication, and usually does not include the content of the conversations. If you are concerned about third parties holding or accessing the meta-data or content of communication please inform me of this and we can explore the use of specialised communication applications to mitigate this.

Note 2 – Modern Smartphone applications upload the location of the phone to the application server. This can result in applications such as Facebook deriving a connection between us. Storage of Information I store information in two forms:
● Digitally
○ Contact information – Name, phone number and email address and email content from our communications. These are held on a laptop, phone and backed up on local devices.
○ SMS Texts -These are held on a phone.
○ Information about financial transactions made to Fran Slater via bank transfer are recorded in the form of bank statements which are accessible digitally via a
banking app.

● Paper form
○ Anonymised case notes derived from information in sessions are held in a locked filing cabinet. Letters, signed consents and agreements, initial assessment forms are held separately to the case notes also in a locked cabinet.

Sharing of Information
Who I may share personally identifiable information with
● Statutory bodies when required to by law or instruction of a court of law or when required to avoid significant harm to you, me, or others.
● My ethical membership body, insurers, professional advisers and Lawyers, in the case of you making a complaint against me.
● My professional executor, in the case of my incapacity or death.
● A lawyer – If your information is requested by a court or you raise a legal action against me I may take legal advice, in order to clarify whether the court has jurisdiction, and whether the request meets the strict legal criteria required in such cases. In this situation I may consult a lawyer to help me make an informed decision about whether to release some or all the information I hold to the court. Personal information pertinent to the decision will be made available to the lawyer, who will be bound by a Professional Code of Conduct.

Who I share anonymised personal information with:
● Clinical Supervisors as required by my ethical membership body, in order to ensure I am operating effectively and ethically.
● Other counsellors who are members of a Professional Register in order to gain insight and information from others with a different perspective.
● Tutors and examiners in order to gain additional qualifications and accreditations.

How long will I keep your information
● Digital Information – Contact information: emails, texts, messages will be erased when counselling has ended. (For technical reasons this information cannot be entirely erased and could therefore remain accessible to a technically competent person until the storage device is destroyed or securely wiped and reformatted)
● Paper information – Assessment form, signed contract, case notes, will be kept for 3 years after counselling has ended and then securely destroyed.

Marketing
I will never use your information for marketing, or contact you to market a service.

Data Security
I take the security of the data that I hold about you very seriously. My email account is password protected and mobile phones and laptops used to respond to your emails are password and/or biometrically protected and have anti-virus software.

Website Visitors
When someone visits my website, I use a third party service, GDPR Cookie Consent, to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. I do not make, and do not allow GDPR Cookie Consent to make, any attempt to find out the identities of those visiting my website. I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website. I use Google Analytics so that I can continually improve my service to you. You can read G.A privacy notice here. Like most websites we use cookies to help the site work more efficiently. 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.

Your legal rights
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. For more information about your Information Privacy Rights or to make an Information Privacy orientated complaint you can contact the Information Commissioner’s Office (ICO) through their website rights at https://ico.org.uk/your-data-matters/

Data Protection Complaints
As a sole trader counselling practice, I take your privacy and data protection rights seriously. If you have any concerns or complaints regarding how I collect, store , or use your personal data or case notes, please contact me directly in writing at hello@franslatercounselling.co.uk.

In accordance with UK data protection laws, I will:

• Acknowledge your complaint in writing within 30 days of receipt
• Investigate the matter thoroughly and respond to you without undue delay
• Provide you with a clear outcome and explain any actions taken.

Please note that under current UK regulations, you are required to attempt to resolve any data protection grievances directly with me first. If we are unable to resolve the issue together, you retain the right to escalate your complaint to the Information Commissioner’s Office (ICO) at www.ico.org.uk.

Changes to this policy

If I have to make changes to this policy that are inconsistent with the original purposes for which your data was collected, I will notify you in advance wherever possible and give you the opportunity to withdraw consent for your information to be processed.