For the purposes of processing your personal data I, Sharon Carley, am the controller and am registered with the ICO.
I only collect personal information for proper and lawful reasons. At every stage of our relationship, your information will be processed only if it meets at least one of the following conditions:
To fulfil my agreement with you. This includes the collection of information before we enter into an agreement, during each session and after the session has concluded. To ensure I am giving you a professional and ethical service that complies with the Codes of Practice of the professional organisations I am a member of and the requirements of my insurers. When it is my legal duty to collect, store, use or transfer information to comply with legislation or the instructions of a court of law. When it is a required to maintain my own safety, your safety or the safety of third parties. To enable financial transactions between us.
How Information is Collected:
The personal identifiable information I collect, store and use comes from our conversations, emails, texts and phone calls. The information others may hold (e.g. the Counselling Directory or Bank) comes from our online communication and/or from financial transactions between us.
Types of Information Held:
Personally identifiable information held: Your contact information, date of birth, occupation and health. Communication from letters, emails, texts and phone calls. Signed agreements regarding counselling, hypnotherapy, personal life coaching or reiki.
Diary appointments are held non electronically and are first name only.
Anonymised information I hold: are case notes.
Digital: Contact information held on phone. This is deleted once our sessions are completed. Emails held on laptop, tablet, phone are deleted once sessions have finished. Emails attaching contact details and agreement are deleted once contact details and signed agreement have been printed. SMS texts are held on a phone and deleted once sessions have finished or enquiry doesn't go any further. Occasionally anonymous case notes are typed on laptop these are deleted once printed out after sessions have completed. Electronic payments. Phone, laptop and tablet are password protected.
Electronic communication is not totally secure and I cannot be held responsible for damage or loss caused by viruses or for communications which are corrupted or altered after dispatch.
On paper: your contact information, date of birth, occupation and health. Signed agreements. Electronic payments (client name is blacked out and anonymously coded). Anonymised session notes, coded and filed separately in locked filing cabinet. Diary appointments using first name only.
Sharing information - I may share personally identifiable information with Statutory bodies when required to by law or instruction of a court of law. Statutory bodies when required to avoid harm to you, me or others. My accrediting/ethical membership body, insurers and professional advisers in the case of you making a complaint against me. My professional executor, in the case of my incapacity or death. A judge - 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.
I share anonymised personal information with my clinical supervisor in order to ensure I am operating effectively and ethically. I am required to do this by the professional organisations I belong to.
For legitimate purposes I will retain your information for 7 years after your last appointment and for 7 years after a child's 18th birthday. After this period I will shred all records.
I do not use your data for marketing purposes.
You have the right to see what personal data of yours I hold and you can ask me to correct any factual errors.
I want you to be confident that I will treat your personal data responsibly and that everything is being done to ensure that no person has access to your data other than myself.
If you feel that I am mishandling your personal data in some way, you have the right to complain. Complaints need to be sent in writing to me. Please call me for the address to send the complaint to.
If you are not satisfied with my response, then you have the right to raise the matter with the Information Commissioner's Office.