Privacy Policy
ICO registration number: ZA464103
Zoë Welsh Therapy collects and processes the following information:
⦁ Your name, address, telephone number(s) and email address for communication purposes, appointment scheduling, payment processing and invoicing
⦁ Information and documentation relating to your therapy, i.e., correspondence, intake assessment information, brief factual case notes
⦁ Audio recordings of sessions, with your prior consent.
*Please refer to the Zoë Welsh Therapy Counselling and Psychotherapy Contract for further details regarding consent to audio record therapy sessions.
Most of the personal information I process is provided to me directly by you for:
⦁ The safe provision of counselling and psychotherapy services under the terms of the Zoë Welsh Therapy Counselling and Psychotherapy Contract
I may, during your treatment receive personal information about you from others involved in your care and welfare, i.e., your GP, consultant, third party agencies
I may, during your treatment be required to share this information with your GP, consultant, and third-party agencies. I am also required to share your personal information under certain circumstances specific to the delivery of counselling and psychotherapy services, i.e., in clinical supervision with my clinical supervisor and with the executor of my Clinical Will,
* Please see the “I will use your information” section below for details.
I will use your information:
⦁ To correspond directly with you for the purposes of scheduling appointments, sending appointment booking/confirmation reminders, processing payments, invoices, and receipts
⦁ In brief factual case notes to include an outline of what was discussed/and or agreed in each session
⦁ For purposes of a Clinical Will. Your contact details only are held by the executor of my Clinical Will throughout the course of your therapy. My executor, a trusted colleague is similarly registered with the ICO (Information Commissioner’s Office) and is also required to store data under the conditions as stated in the GDPR as it applies in the UK, tailored by the DPA 2018. Once you have been contacted by my executor s/he will delete your personal data.
⦁ In clinical supervision with my clinical supervisor who is similarly registered with the ICO (Information Commissioner’s Office) and is similarly required to store data under the conditions as stated in the GDPR as it applies in the UK, tailored by the DPA 2018. This is in order to meet the professional standards required of all practicing counsellors and psychotherapists. NB: For the purposes of supervision, I will use your first name only or a pseudonym.
Under the General Data Protection Regulation (GDPR), the lawful bases I rely on for processing this information are:
Your consent. You can remove your consent at any time. You can do this by emailing info@zoewelsh.co.uk
I have a contractual obligation i.e., to provide counselling and psychotherapy services under the terms of the Zoë Welsh Therapy Counselling and Psychotherapy Contract
I have a vital interest i.e., if I consider your welfare or the welfare of others to be seriously at risk
I have a legitimate interest i.e., in order undertake the necessary administration to provide counselling and psychotherapy services under the terms of the Zoë Welsh Therapy Counselling and Psychotherapy Contract
How I store your personal information
⦁ Your contact information is stored electronically on a password protected laptop, a password protected external hard drive and for the purposes of communication only a password protected mobile phone.
⦁ Hard copies of your case notes are securely stored in a locked filing cabinet for the duration of your treatment only and securely shredded thereafter. Case notes are stored under a client ID number only.
⦁ Your contact information and case notes are retained by me electronically on both a password protected laptop and a password protected external hard drive for a period of five years from the end of your treatment. This is a requirement of my accrediting body, my insurers and HMRC. At the end of this period, I will securely delete/destroy your personal information as detailed above.
Your data protection rights
Under data protection law, you have rights including:
Your right of access - You have the right to ask me for copies of your personal information.
Your right to rectification - You have the right to ask me to rectify personal information you think is inaccurate. You also have the right to ask me to complete information you think is incomplete.
Your right to erasure - You have the right to ask me 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, i.e., if the data is inaccurate or there is a dispute about whether your interests override the legitimate grounds for processing data.
Your right to data portability - You have the right to ask that I transfer the personal information you gave me 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, I have one month to respond to you.
Please email info@zoewelsh.co.uk if you wish to make a request.
How to complain
If you have any concerns about my use of your personal information, you can make a complaint to me by emailing: info@zoewelsh.co.uk
You can also complain to the ICO if you are unhappy with how I 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