The General Data Protection Regulation (GDPR)
This privacy policy governs the manner in which Jane Frajbis at Restoration Counselling uses, maintains and discloses information collected from clients using Jane Frajbis’ ‘Restoration Counselling’ counselling, psychotherapy and supervision services. This privacy policy applies to the practice, website and services offered by Jane Frajbis, online, by telephone or within her private practice.
I am Registered with the ICO (Information Commissioner’s Office) (Reg No: ZA259280), and comply with the GDPR (General Data Protection Regulation). You may request details of personal information which I hold about you under the Data Protection Act 2018. If you would like a copy of the information held on you, please write to me, Jane Frajbis, at Restoration Counselling, 14 Hawthorn Way, Higher Compton, Plymouth, PL3 6TP.
(Clients seeking therapy will be issued with a paper copy of the Privacy Policy at their Initial Assessment which contains the following information & they will be asked to sign that they understand & agree with how information is collected, stored & held before therapy can commence).
Personal Information I collect:
- Name and dob
- Occupation
- Address
- Preferred contact number
- Counselling History
- Medical conditions relevant to counselling
- Medications
- Client expectation from counselling
How I store information:
Handwritten notes pertaining to sessional content & personal details are kept separate in a locked cabinet.
Smart phone: My smart phone is locked & is only accessible using a password. I store your contact number but I do not save any names to numbers.
Email /Texts: Email addresses are stored in my Outlook account. Text messages are only assigned to numbers not names.
Website. No personal information is stored on my website other than to momentarily collect & send enquiries to my outlook account for initial contact purposes.
Third party websites: Clients may find content on my website that link to the sites of other third parties. I do not control these sites which have a link to mine and I am not responsible for how they collect, store or use information
- Internal record keeping.
- I may use the information to improve my services.
Documents Held:
- Contract/Agreement form (client is issued with a copy at commencement of counselling & copy held by the counsellor for reference.)
- Privacy statement signed by client (client is issued with a copy at commencement of counselling & copy held by the counsellor for reference.)
- Assessment / intake form
- Client code
- Client sessional notes, kept for 7 years to comply with Insurance policy terms.
How I may share your personal information:
- Supervision: I attend monthly clinical supervision to ensure my practice remains safe & ethical. Session details & client codes may be shared with my Supervisor. No identifying information will be shared with her.
- Therapeutic Will: Your name & contact details will be shared with my Therapeutic Executor so that in the unlikely event of my sudden death you can be contacted should you still be in therapy with me. My Therapeutic Executor will sign a confidentiality agreement document.
- Emergencies: If your health is in jeopardy I may share your details with a healthcare service such as your GP or Mental Health Crisis Team.
Erasing your information:
All electronic enquiries are erased after 3 months. All texts & contact numbers are erased 3 months following the cessation of therapy.
I hold your written information for up to 7 years following the cessation of therapy. This is so I have a reference should you decide to return to therapy in the future, as well as for insurance purposes.
Your Rights:
- Right to Access: You have the right to ask for a copy of your personal information, free of charge, in an electronic or paper format. You also have the right to ask me to amend or change any incorrect information about you.
- Right to be Forgotten: You have the right to ask me to erase any information that I hold about you. This includes your personal information that is no longer relevant to original purposes, or if you wish to withdraw consent. In all cases and when considering such requests, these rights are obligatory unless it’s information that I have a legal obligation to retain.
- Data Portability: As the client, you have the right to receive your personal information which you previously provided, also you have the right to transfer that information to another party. For the purposes of the General Data Protection Regulations (GDPR) 2018, the data “controller” is Jane Frajbis (Restoration Counselling).
Complaints:
If you are unhappy with the way that I have handled your data, you are able to make a complaint. The process for this is as follows:
- Should you need to make a Data Protection complaint, in the first instance, please contact me in writing via email: jane@restorationcounselling.co.uk or by post and send to: 14 Hawthorn Way, Plymouth, PL3 6TP. I will acknowledge any complaint within 30 days.
- If you are unhappy or dissatisfied with the way that I have handled your data and/or processing of your complaint, please contact the Information Commissioner’s Office (ICO) directly on: https://ico.orguk/global/contact-us-public/ or: https://ico.org.uk/make-a-complaint/data-protection-complaints/. Or call the ICO on: 0303 123 1113