Privacy Policy
Introduction
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 your personal information from initial point of contact through to after your therapy has ended, including:
• Why I am able to process your information and what purpose I am processing it for
• Whether you have to provide it to me
• How long I store it for
• Whether there are other recipients of your personal information
• Whether I intend to transfer it to another country
• Whether I do automated decision-making or profiling
• Your data protection rights
I am happy to chat through any questions you might have about my data protection policy, and you can contact me via email at vicky@gentleconnections.co.uk.
Data Controller
‘Data controller’ is the term used to describe the person/organisation that collects, stores, and has responsibility for people’s personal data. In this instance, the data controller is me:
Vicky Martin
Gentle Connections Counselling Service
ICO Registration Number: ZB676316
Suite 12A, The Whitehouse, 42–44 Chorley New Road, Bolton, BL1 4AP
Tel: 07449 003189
Email: vicky@gentleconnections.co.uk
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. These vary depending on the stage of our engagement:
If you are currently having therapy or are in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of our contract.
If you have previously had therapy with me and it has now ended, I will use legitimate interest as my lawful basis for holding and using your personal information.
For special category personal information (such as details about your emotional or physical health), I will rely on your explicit consent to begin with, and thereafter retain this information as necessary to defend against potential legal claims.
How I Use Your Information
Initial Contact
When you contact me to enquire about counselling services, I collect information to help address your enquiry. This may include your name, address, telephone number, email address, GP details, and a designated emergency contact. This may be provided directly by you, or by someone acting on your behalf (such as a parent or healthcare professional).
If you decide not to proceed with counselling, I will delete your personal data within 14 days unless you ask me to delete it sooner.
While You Are Accessing Counselling
Everything you share with me is confidential. Confidentiality will only be broken if I believe there is a risk of serious harm to you or others, or where I am legally obligated to do so under legislation such as:
The Terrorism Act 2000
Drug Trafficking Act 1994
Proceeds of Crime Act 2002
Money Laundering Regulations 2007
Road Traffic Act 1991
Children Act 1989
Serious Crime Act 2007
Female Genital Mutilation Act 2003
Where possible, I will always discuss this with you first.
I keep a record of your personal details to help the counselling process run smoothly. These are stored securely on an encrypted and password-protected device and are not shared with third parties.
I also keep brief, anonymised written notes of each session. These are stored on a secure, encrypted digital system and are accessible only by me.
Text Messages: I do not retain text messages for more than 7 days. If any relevant information is shared by text, I will record it securely in your client notes.
Emails: Emails are deleted within 30 days unless they form part of your client record, in which case the relevant content is copied into your notes and stored securely.
After Counselling Has Ended
Once therapy has ended, I will retain your records for seven years from the date of our last contact. This is standard practice in line with professional guidance and insurance requirements. After this period, your records will be securely destroyed. If you would like your records to be deleted sooner, you can make this request in writing.
Third Party Recipients of Personal Data
I may share personal data with trusted third parties, such as administrative or technical support providers. Any third party I engage is contractually bound to handle your data only for the specific purpose agreed and must adhere to strict confidentiality and security standards. Your data is never sold or used for marketing.
Your Rights
You have the right to:
• Request access to the personal information I hold about you
• Ask me to correct any inaccuracies
• Request that your personal data be erased or processing restricted
• Object to the processing of your data
• Lodge a complaint with the Information Commissioner’s Office if you believe I have mishandled your data
To make a request, please contact me in writing at:
vicky@gentleconnections.co.uk
More information about your rights is available at ico.org.uk/your-data-matters
Data Security
I take the security of your data very seriously. All client records are stored securely. I use encrypted, password-protected digital devices, and any paper records are kept in a locked filing cabinet. Access to client information is strictly limited to me.
Visitors to My Website
When you visit my website, I use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. This helps me understand how visitors use the site. This information is processed in a way that does not identify individuals.
I use legitimate interest as the legal basis for collecting website analytics.
My website is built and managed through Squarespace. You can read more about how Squarespace handles data here: https://www.squarespace.com/privacy
You can read Google Analytics’ privacy policy here: https://support.google.com/analytics/answer/6004245
My website uses cookies to help the site function more effectively. You can read my Cookie Policy here:
If you fill in a form on my website, that data is temporarily stored by my website host before being securely sent to me.