Data Protection & Privacy Policy

Introduction

Your privacy is very important to me and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to me. I adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

This privacy notice tells you what I will do with your personal information from initial point of contact through to after your therapy and coaching has ended, including:

• Why I am able to process your information and what purpose I am processing it for

• Whether you have to provide it to me

• How long I store it for

• Whether there are other recipients of your personal information

• Whether I intend to transfer it to another country

• Whether I do automated decision-making or profiling

• Your data protection rights

I am happy to chat through any questions you might have about my data protection policy – you can contact me via email: .

‘Data controller’ is the term used to describe the person/organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is me, Lorna Lythgoe.

I am registered with the Information Commissioner’s Office (ICO) and my registration number is ZB511235.

My postal address is: 19 Windsor Place, Edinburgh, EH15 2AJ. My phone number is: 07584 639036.  My email address is: .

My lawful basis for holding and using your personal information

The GDPR states that I must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which I am processing your data. I have explained these below:

If you have had therapy with me and it has now ended, I will use legitimate interest as my lawful basis for holding and using your personal information.

If you are currently having therapy or if you are in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of our contract.

The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for me processing any special categories of personal information is consent initially. I will then retain any therapy and coaching records in case of the need to reference them in the future (the official legal basis is to defend against potential legal claims).

How I use and protect your information

Initial contact.

When you contact me with an enquiry about my counselling and coaching services, I will collect information to help me satisfy your enquiry. This will include your name, email address and phone number. Alternatively, your GP or other health professional may send me your details when making a referral or a trusted individual may give me your details when making an enquiry on your behalf. If you decide not to proceed, I will ensure all your personal data is deleted within six months. If you would like me to delete this information sooner, just let me know.

During our initial appointment, I will ask you about your availability, aims and circumstances, including your personal history and issues that are affecting you now.  I require this information so that I can decide whether I can offer you a counselling/coaching service and how to manage the service I provide you.  If you decide not to proceed, I will ensure all your personal data is deleted within six months. If you would like me to delete this information sooner, just let me know.

While you are accessing counselling and coaching.

If you decide to proceed with coaching or counselling, I will ask you to read and sign a coaching/therapy agreement in which I will ask for your name, email address, phone number, and GP or other emergency contact details.  I will keep a record of your personal details to help the counselling and coaching services run smoothly.  All electronic records are stored securely on a cloud server using the latest firewalls and data security protocols, and all access is by password-protected authentication.  They are not shared with any third party.

Rest assured that everything you discuss with me is confidential. I will only share your information with professional carers or others whom you have requested or agreed I should contact. 

Confidentiality will only be broken if I have reason to believe this will prevent serious harm being caused to you or another person, or if I am required to by law.  I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.

I will keep written notes of each session, which are stored securely on a cloud server using the latest firewalls and data security protocols, and all access is by password-protected authentication.  They are not shared with any third party.  Furthermore, your session notes and other descriptive material are anonymised and kept separately from any identifiable personal information.

For security reasons, I do not retain text messages for more than three months. If there is relevant information contained in a text message I will transfer the written content to your secure and anonymised digital file. Likewise, any email correspondence will be deleted after three months. If there is relevant information contained in an email, I will transfer the written content to your secure and anonymised digital file.

After counselling and coaching has ended.

Once therapy and coaching has ended, your records will be kept for three years from the end of our contact with each other and are then securely destroyed. If you want me to delete your information sooner than this, please tell me.

Your rights

I try to be as open as I can be in terms of giving people access to their personal information.  You have a right to ask for a copy of any information that I hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at: ico.org.uk/your-data-matters. You also have a right to ask me to delete your personal information, to limit how I use your personal information, or to stop processing your personal information.  Please note, though, that if you do this while actively receiving counselling or coaching with me, your counselling/coaching would have to end, as I abide by the BACP ethical framework which requires me to keep accurate client records.  For more information, please see: https://www.bacp.co.uk/events-and-resources/ethics-and-standards/ethical-framework-for-the-counselling-professions/   

If I do hold information about you I will:

• give you a description of it and where it came from;

• tell you why I am holding it, tell you how long I will store your data and how I made this decision;

• tell you who it could be disclosed to;

• let you have a copy of the information in an intelligible form.

You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you.

To make a request for any personal information I may hold about you, please put the request in writing addressing it to .

If you have any complaint about how I handle your personal data, please do not hesitate to get in touch with me by writing or emailing to the contact details given above. I would welcome any suggestions for improving my data protection procedures.

If you want to make a formal complaint about the way I have processed your personal information you can contact the ICO which is the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint.

Data security

I take the security of the data I hold about you very seriously and, as such, I take every effort to make sure it is kept secure by storing all electronic records securely on a cloud server using the latest firewalls and data security protocols, and by using password-protected authentication for all access.  I also anonymise your session notes and other descriptive material keep them separately from any identifiable personal information.

Please note that, although I will do my best to protect your information from unauthorised access using industry-standard protocols and encryption, the transmission of information via the internet is never completely secure.  I cannot guarantee the security of your data transmitted to me via email, including forms completed on my website which are transmitted by email.  As such, any transmission is at your own risk.

Visitors to my website

When someone visits my website, I use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. I do not make, and do not allow Google to make, any attempt to find out the identities of those visiting my website.

I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.

I use Google Analytics so that I can continually improve my service to you.  You can read Google Analytics’ privacy notice here: https://policies.google.com/privacy.  

Like most websites we use cookies to help the site work more efficiently – find out about my use of cookies: https://allaboutcookies.org/

Where required, user-specific data is collected by secure third party services (e.g. Appointlet for booking Zoom calls with me). If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.

Adapted from bacp.co.uk

V2.0 – updated Sept 23