Privacy and Confidentiality Policy
The counsellors at The Counselling Group Practice (The CGP) respect your right to privacy, and the laws relating to data protection.
Please find below our group statement and commitment to clients. This is a working document which The CGP counsellors endeavour to update regularly and in accordance with legal amendments. Additionally, The CGP counsellors will discuss confidentiality and privacy with you when contracting in your initial appointments.
Terminology
The UK data protection regime is set out in the Data Protection Act 2018 and the General Data Protection Regulation (GDPR). Data protection is about respecting the fair and proper use of information about people.
The Information Commissioner’s Office “ICO” is the UK’s independent body upholding information rights in the public interest. The CGP counsellors are each individually registered with the ICO and individually responsible for protection of your data and the maintenance of this website.
“The Counselling Group Practice” and “The CGP” are the names used for a collective website presence for marketing the seven counsellors and do not denote a separate legal entity. Each individual counsellor is responsible for their work with you and will aim to be clear and transparent about use of your data, and will enter into a unique contract with you, confirming your consent to the processing of your personal data for the purposes of providing you with counselling services. As a group, we feel strongly about client safety and wellbeing, so we have drafted a set of policies which set out the minimum standards you can expect when working with one of us. Each counsellor aims to adhere to all legal obligations and professional commitments and is guided by the British Association of Counselling and Psychotherapy (BACP).
Confidentiality and Contracting Data Storage with your Counsellor
Your counsellor’s work with you is confidential. Your counsellor will explain how your data will be held. You will be invited to consent to your counsellor using your data in this way. The personal data requested will usually include your name, address, contact telephone and email address, as well as any other relevant information.
Your phone number and email will be held on your counsellor’s phone purely for arranging counselling sessions. The CGP counsellors’ phones are all password protected and only your individual counsellor has access to their phone.
Your counsellor will not sell your information, and it will only be shared upon your request, or with your consent or where required to do so in exceptional circumstances.
WEBSITE EMAIL CONTACT FORM
The business Webhealer operates and maintains our website and host The CGP email. Content of your email is neither available to Webhealer staff nor stored on its systems. Your email will not be seen by any other CGP counsellor.
ONLINE COUNSELLING SESSIONS
The CGP counsellors make every effort to ensure they are working from a secure platform, and we suggest that you similarly take all appropriate steps to ensure the security of your own online presence.
SOCIAL MEDIA
To protect the privacy of our clients, The CGP counsellors do not to extend client-counsellor relationships to social media.
EXCEPTIONAL CIRCUMSTANCES - BREAKS OF CONFIDENTIALITY
You may instruct us in writing to disclose such information as you specify to a third party.
In exceptional cases, specifically a revelation by a client of intention to cause serious harm to themselves or others; involvement with terrorism; involvement with money laundering; counsellors may have a professional, ethical, or legal duty to break confidentiality and inform relevant services.
In case of risk of harming yourself, your counsellor may request the name and address of your General Practitioner with the purpose of providing you further support.
Your counsellor will endeavour to discuss any break of confidentiality with you first.
Help Protect Your Own Privacy
YOUR CONTACT WITH YOUR CGP COUNSELLOR:
The CGP counsellors suggest that NO SENSITIVE PERSONAL INFORMATION be shared other than during counselling sessions and that contact between sessions, by phone call, text or email is limited to arranging sessions. Whilst the CGP counsellors make every effort to protect confidentiality, all data that is transmitted electronically is done at your own risk.
GENERAL DATA PROTECTION REGULATION (GDPR)
The GDPR requires each counsellor to state the lawful basis for holding and processing your personal data (e.g. your name and email address) and sensitive personal data (known as special category data - e.g. information about your health or religion). Unless stated otherwise by your individual counsellor, the legal basis for processing your personal data is ‘legitimate interests’, and for your special category data is ‘necessary for the provision of healthcare’.
KEEPING UP TO DATE
Each counsellor needs to keep your data up to date, and it is your responsibility to inform them of any relevant updates such as change of contact details.
RECORDS AND NOTE-KEEPING
Your CGP counsellor will define how any information or material beyond contact information is confidentially and securely stored.
CGP counsellors will keep ‘Session Notes’, recording time and place of meeting and perhaps brief details of the session and will make every effort that individuals are not identifiable.
Some CGP counsellors will use creative/art interventions. All work created in session is yours. Usually this will be given to you to take away at the end of the session. If you do not wish to hold it, you can discuss its storage or disposal with your counsellor. Your counsellor will handle all items with the same confidentiality and security as other personal data.
ACCESS TO RECORDS
You can request in writing to see the Session Notes at any point during the counselling.
STORAGE AND DELETION OF DATA
At any point you can request that your counsellor delete your personal data with the exception of data that your counsellor’s professional insurers or the BACP require them to retain for a specific period of time, or providing there is no other reason (such as a legal one) preventing your counsellor for deleting your records.
At the end of your counselling, your data will be held securely for up to 7 years depending on circumstance, after which it will be permanently and securely destroyed.
Counsellor Incapacitation
In the event your counsellor becomes ill or otherwise unable to contact you, each CGP counsellor has a system whereby you will be informed.
Each counsellor has appointed a professional therapist, who at the relevant time will be able to access your name and contact details to help discuss your ongoing counselling requirements. Your counsellor will obtain your consent to use your data in this way, in their initial contract with you. This appointee will ensure your data continues to be stored and ultimately deleted securely.
Supervision
In accordance with BACP guidelines, all The CGP counsellors have regular supervision. Client confidentiality is always strictly upheld, and your counsellor will explain how they do so.
Contact your Counsellor
To request further information at any point, please contact your counsellor in writing at the following addresses:
Adela Victoria Small - Avictoria@thecgp.co.uk
Ann Northover - Ann@thecgp.co.uk
Bronwyn Basham - Bronwyn@thecgp.co.uk
Clare Parfitt - Clare@thecgp.co.uk
Courtney King - Courtney@thecgp.co.uk
Emma Williams - Emma@thecgp.co.uk
Kristin Ramsey - Kristin@thecgp.co.uk