General Data Protection Regulation (GDPR)
Mindwell Therapy acts as a Data Controller and collects and processes personal data of clients to carry out its functions. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations.
Data Controller: Mindwell Therapy.
Data collected and reason for collection:
– Personal Data: Name, address, telephone number and email address in order to be able to contact you
– GP details, in line with duty of care and medical emergencies
– Emergency contact details in case of personal or medical emergencies
– Any personal information provided during sessions, such as age, marital status, children, date of birth, gender, occupation and ‘special category data’ such as race, ethnic origin, politics, religion, health, sex life or sexual orientation.
Reason for collection:
– to be able to contact you if necessary
– in case of personal or medical emergencies
– to comply with the recommendations of our professional body and insurance company
The lawful basis on which we use this information:
To collect and use data you share, we must show the ICO that we have a lawful basis to do this. We also need to tell you what this lawful basis is.
We have determined that ‘legitimate interests’ is the most appropriate lawful basis for both personal (article 6) and special category data (article 9). See https://bit.ly/2FLs0Bu for more details.
How we store your data:
Your data will be stored in a fireproof lockable cabinet. Notes taken during sessions are held separately to personal data detailed above and are not identifiable with your personal data. The only data held electronically is your telephone number and name. This is on a separate password protected mobile phone.
How long we will keep your data:
Your data will be kept for the duration of our work together. When our work together has finished, all data except for session notes (which will be stored for up to 7 years as per recommendations of our professional body and insurance company) will be shredded and securely disposed of.
How your information may be shared:
We would only share data in line with ethical and legal obligations. These are:
– During our supervision sessions when we may talk about our work together. However only your first name would be used.
– If we receive a Court Order for the release of our notes.
– If you disclose you are at risk of serious harm to yourself or another.
– If you share information about a proposed act of terrorism/money laundering/drug trafficking.
– If there is a request by the Police for information regarding a road traffic accident.
You have the right:
– to be informed about what information we hold – a copy of this document will be available during our first session.
– to access the information we hold – you can request this verbally or in writing at any time. We will provide you with the information within one month.
– to have any incorrect information rectified – you can request this verbally or in writing.
– to have your records erased (in the defence of any legal claims, we may decline to do this citing the lawful basis of legitimate interests)
– to restrict processing (we may decline to do this citing the lawful basis of legitimate interests)
– to data portability – e.g. you can request your notes be transferred to another counsellor.
– to object to processing of your data (we may decline to do this citing the lawful basis of legitimate interests)
If you have any concerns about how we have used your data please contact the Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF – Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate).
If you would like to discuss anything in this privacy statement, please contact firstname.lastname@example.org
Last updated May 2018
Angela Holt PG Dip, MBACP
Mindwell Therapy, RB House, 103 Washway Road, Sale, M33 7TY