Date: 20/05/2022
Version: 1
Our contact details
Name: Mark Henwood T/A mjh counselling
Address: c/o 46 West Way, Bournemouth, BH93EB
E-mail: mark.henwood@mjhcounselling.co.uk
The type of personal information we collect
We currently collect and process the following information:
- Personal identifiers, contacts and characteristics (for example, name, address, contact details, gender, ethnicity)
- Family information and background
- Medical information – including medication, well-being and GP details
- Clinical notes, based on session content
- Website user statistics
- The above includes some special categories of personal data
How we get the personal information and why we have it
Most of the personal information we process is provided to us directly by you for one of the following reasons:
- To make an enquiry for counselling
- To fulfil the counselling process
- To manage health/safety/safeguarding legal/ethical requirements.
We also receive personal information indirectly, from the following sources in the following scenarios:
- Referral organisations – those who may refer individuals for counselling
- Medical Authorities – where a specific request for records has been given consent, in order to support the counselling process.
We use the information that you have given us in order to provide appropriate and ethically sound counselling services or to refer on.
We may share this information with medical professionals, supervision professionals or as part of our ethical requirement to maintain a clinical will. We may share information with your consent as part of an onward referral. We may also refer to safeguarding or legal bodies where a legal requirement exists.
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:
(a) Your consent. We ask for your consent to share counselling information with other mental health or medical professionals, if clinically appropriate. You are able to remove your consent at any time. You can do this by contacting mark.henwood@mjhcounselling.co.uk
(b) We have a contractual obligation. Your contract for counselling services will require that I abide by ethical principles of counselling, as laid down with the BACP and as such, I will need to process and maintain certain of your information in accordance with this framework.
(c) We have a legal obligation. There are limits to confidentiality laid down in law and I may be required to process certain information to fulfill my legal requirements.
(d) We have a vital interest. In the event of potential serious / imminent harm to you or someone else, we may share certain of your data.
(e) We need it to perform a public task. Where my services are contracted via a Public body.
(f) We have a legitimate interest. Ethical Counselling requires that I process appropriate information regarding you and your presentation.
How we store your personal information
Your information is securely stored. We use both hard copy file records stored in locked furniture as well as digital records stored using Microsoft 365 and Google Drive, all protected by password security and web protection via Norton. Our email service provider is through Microsoft Exchange and our web provider is with Word Press, including their approved web app associate providers and IONOS.
We keep information for the following time periods.
Application form / Assessment Details – 7 years from end of counselling
Clinical notes – 7 years from end of counselling
Relevant Communications – 7 years from end of counselling
We will then dispose of your information by secure shredding or secure file deletion.
Your data protection rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at mark.henwood@mjhcounselling.co.uk if you wish to make a request.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at mark.henwood@mjhcounselling.co.uk.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk