Privacy notice

How do I protect your personal data?

On this page you can view my Privacy Notice and find a link to my Cookies Policy.

When you trust me with your personal data, I take my responsibility to protect it very seriously. I respect your privacy and your rights to control your personal data, within the limits of the law and any Agreement we make about your therapy.

My Privacy Notice (below) explains how I collect and use any personal information about you during and after your therapeutic relationship with me. It also explains your rights as relating to your personal data. My Cookies Policy explains more about how your data is used when you use my website.

Data protection law in the United Kingdom

In UK law, the General Data Protection Regulation (GDPR) is concerned with protecting your personal information. My Privacy Notice and Cookies Policy are designed to meet these requirements. These apply from when you first contact me or access my website.

PRIVACY NOTICE

1. About this Privacy Notice

This Privacy Notice explains how I collect and use any personal information about you during and after your therapeutic relationship with me. The General Data Protection Regulation (GDPR) is concerned with protecting your personal information. This Privacy Notice explains how I comply with that.

When you trust me with your personal data, I take my responsibility to protect it very seriously. I respect your privacy and your rights to control your personal data, within the limits of the law and any Agreement for therapy that we make. Please read this Privacy Notice carefully to understand my practices regarding your personal data, and make sure you understand it.

2. Basic information for data protection purposes

My name:                                            Julian Mauger, also known as ‘Juline’.

My email address:                            juliancounselling@gmail.com

My telephone number: 07963 740048

Data controller                                  Julian Mauger

Data protection officer: I do not employ a data protection officer.

My ICO registration certificate reference number is: ZA222953.

3. Purposes of the processing of your personal data

You are always at liberty to decide whether to provide or withhold personal information that I request from you. If you choose not to, or fail to, provide that information, I may be limited in what services I can provide you for ethical or legal reasons. I will let you know how this will affect you at the time.

The purposes of collecting and processing your data are as follows.

• The provision to you of counselling and psychotherapy services. This includes the therapeutic service itself; administration of the service; communicating with you about any clarification of or changes to services provided; the processing of payments; dispute resolution; and the conclusion of any other matter with you in relation to services provided after the therapeutic relationship has ended.
•  The notification to third parties of certain circumstances arising, in line with my Confidentiality and Disclosure Policy, which I will give you when we make an Agreement for therapy.
• The keeping of records for an appropriate length of time of records in line with legal or ethical requirements, including
  • Meeting the requirements of any professional body with which I am registered
  • To meet the requirements of my insurers under the terms of my policy with them
  • For income tax records.
• Analysis of data in anonymised form to better understand the performance of my website(s) or effectiveness of advertising methods.

The types of personal information I collect and record

The personal information I usually collect and/or record is of four types, as follows

1. Information that I will collect from you as a minimum in order for counselling and psychotherapy services to be provided:

• Your name
• Date of birth
• Your postal address
• Your preferred contact details such as email address and phone number
• Your GP details
• Difficulties you are facing and the reasons you want counselling/psychotherapy
• Details of any other counselling, psychotherapy or mental health services you are currently engaged with

I rely on you to ensure that your personal information is complete, accurate and up to date. You agree to inform me promptly of any changes to or inaccuracies in your personal information.

2. Information that I may ask you for, but not necessarily require from you, if you do not wish to provide it:

• Your occupation
• Details of mental health professionals you are engaged with (or have been) if they might needed to be contacted for urgent care if needed
• Medical conditions relevant to your counselling/psychotherapy requirements
• Prescribed medication for mental health conditions or otherwise relevant to your counselling/psychotherapy
• Your history of interaction with counselling, psychotherapy and mental health services
• Other personal information that is relevant to the ethical management of the service to be provided to you

3. Other information that you choose to give me

In the course of counselling or psychotherapy, you are likely to disclose further information about yourself. In doing so, it would be quite usual to disclose data that is considered under the law (‘the GDPR’) to be Special Category Data. This means:

• data concerning physical health, mental health, your sex life or sexual orientation
• personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership
• genetic or biometric data.

Under the GDPR, your explicit consent is required if you want me to receive, store and use Special Category Data that you give me. By signing an Agreement for therapy, you will be giving your explicit consent to do so.

4. Session notes

• I make brief session notes to record and inform the work we do together. This is an ethical requirement of my professional membership body (and most other such bodies). These notes are hand-written and not stored electronically.

4. The lawful basis for processing your data

The legal basis on which I process your personal information, including any Special Category Data that you provide is as follows.

• Processing your data is required to be able to deliver the services included in any Agreement for therapy that we make and any specific steps you have asked me to take before entering into this Agreement.
• Processing your data may be necessary to protect your life or the life of another person.

5. How I store and protect your data

General

I store your personal data in paper records. I also store your data in electronic systems, but only those you have knowingly engaged with, for example email, website contact forms, text (SMS), instant messaging, video and audio conferencing, etc.

Data security is of great importance to me. To protect your data, I have put in place suitable physical, electronic and managerial procedures to safeguard and secure you data and ensure it is treated in line with this Privacy Notice. I will always do my best to protect your personal data as outlined in this Privacy Notice, but there can never be total security of any data.

Paper storage

Where your personal information is stored in paper format, it is held in locked storage.

Electronic systems

Where I use third party suppliers of electronic systems, I take all reasonable steps to ensure that your personal data is handled safely and securely to comply with my and the suppliers’ obligations under data protection law.

However, the transmission of information via electronic means is never completely secure. I cannot guarantee the security of your data transmitted between you, me or any third party. In using third party suppliers, none of your personal information is passed by me to these providers. However, use of these systems for communication between you and me may leave a digital footprint. All such electronic systems may be vulnerable to hacking, viruses, unintended forwarding, replication, human error, intrusion through security breach and intrusion through the system provider accessing communications.

Transmission is at your own risk. For this reason, it is best to rely on electronic communication for non-confidential matters only and to sensitive personal data, including psychological material “in the room” as far as possible.  This will not be at all possible for sessions where we are working online, whether on a temporary or permanent basis. The digital footprint will be much greater.

Storage of your anonymised data (which is not ‘personal data’ under data protection law) may be held in electronic format.

You can read more here about online therapy.

6. Confidentiality and the disclosure of your personal data

I regard all data and information you provide me as confidential. This is central to the therapy relationship. However, there are limits to this confidentiality. You should note that I may disclose your personal information to another person in certain limited circumstances. These matters are covered in my Confidentiality and Disclosure Policy which will be given to you when we sign any Agreement for therapy.

7. Retaining your personal information

I will retain your personal information for as long as necessary to

• provide services to you and to complete conduct of all business between us, including administration, matters of payment, dispute resolution with you and/or any third parties, and any other outstanding matters.
• The keeping of records for an appropriate length of time of records in line with legal or ethical requirements, including
  • Meeting the requirements of any professional body with which I am registered
  • To meet requirements of my insurers under the terms of my policy with them
  • For income tax records.

All personal information I retain will be subject to this Privacy Notice and my retention guidelines. I also retain data in an anonymous form for statistical and analytical purposes, for example, to understand how clients interact with my services, including my website(s).

Initially, I retain all your personal information collected in either electronic or paper form for up to 12 months after all business between us has been concluded.

Once no longer needed for on-going business purposes, I convert into paper records any electronic communications that I decide need to be kept as part of your record and permanently delete the rest. I retain these and all other paper-based records for six years after business with you is completed or longer if required by ethical, insurance or legal frameworks in force at the time.  After this time, they are shredded. Please request my Data Retention Policy if you need more information.

I may also keep data in anonymised form so that no individual can be identified from it, e.g. for understanding how my clients discovered my services. This is no longer subject to the same legal requirements.

8. Your Rights

You have the right in law

• To be told what information I hold about you
• To be told what data processing is taking place.
• To see the information that I hold about you. You can ask for a copy of your personal data held by me.
• To ask me to correct any inaccurate or incomplete personal information or inform me about any changes to your personal information
• To request that your personal data be transferred to another person (data portability)
• To withdraw consent to me using your personal information.
• In certain situations, to ask that I restrict processing of, or to object to processing of, your personal data
• In certain situations, to ask that I delete personal information that I hold about you.

All of the above are free of charge. However, some of these rights are limited.  For example, I cannot delete your personal information when you ask me to where the legal, regulatory or ethical frameworks require it to be retained, or if I retain the data as set out in Section 7 above.

In other cases, if I stop using or delete your personal information at your request, I may not be able to continue to provide services to you, such as psychotherapy. I will tell you if I am unable to comply with your request, or how your request might impact on you.

Other information needed to enable you to exercise your rights

No personal information is collected without your knowledge.

I do not use automated decision making.

9. Links to other websites

Please be aware that my website(s) and other documentation may contain links to third party websites that are not covered by any Agreement for therapy that we make or this Privacy Notice. I have no control over how your data is collected, stored or used by other websites. Please check the privacy policies and practices of any such websites before providing any data to them.

10. Complaints about handling your personal information

I am committed to protecting your personal data and to working with you to obtain a fair resolution of any complaint or concern you may have about how it is handled. If you have any concerns about this, please let me know and I will try to resolve your concern.

Although I encourage you to contact me in the first instance if you have any concerns, you do also have the right to complain about to the Information Commissioner’s Office (ICO). You can contact them via their website https://ico.org.uk/global/contact-us/ or by calling 0303 123 1113.

11. Cookies

Cookies are small text files that are stored by your browser (for example, Google Chrome, Safari or Microsoft Edge) on your computer or mobile phone. They are widely used in order to make websites work or to work more efficiently. They are sometimes used to track information about you.  Like many websites, I use cookies to improve your experience and gather information about visits to our websites. For more information, please see my Cookie Policy

12. Changes to this Privacy Notice

This Privacy Notice is version 6.1.2. It was last updated on 12 May 2020.