GDPR Policy for Counselling sessions
The General Data Protection Regulation (GDPR) relates to any of your personal information that I may collect, store or share. This page outlines my GDPR/privacy policy.
While I am based in Stockholm, Sweden, I am registered with the Information Commissioners Office in the UK (ICO) (security number CSN5986266) and adhere to the GDPR guidelines. As I am self-employed, I operate as the data controller for Nine Keys.
Personal information that I collect
When you contact me and as part of our initial assessment, I will ask you for the following information:
- Name (including pronouns), telephone number, email address, address
- Date of birth
- Neurotype e.g. ADHD, autism, dyslexia, giftedness
- Gender, sexual and relationship identity
- GP name and address, plus neurotype, and any information around medical conditions or appointments relevant to counselling or that may present in the counselling room
- Emergency contact and relationship to you
- Counselling history and current reasons for seeking counselling
How I will store your information
Mobile phone
I will store your contact information (name, mobile number) on a mobile phone that is reserved for my therapy work. This allows me to contact you when necessary, but does not allow the information to be shared elsewhere. I use WhatsApp for business on this phone to send messages, so any correspondence between us will also be stored there, unless you choose otherwise.
No emails will be accessed or stored on this phone. Should we ever use WhatsApp SMS for our sessions, then a record of our correspondence will be stored there until you or I delete it.
Laptop
Our counselling contract and any emails will be stored electronically on a password protected laptop that will be kept in a locked filing cabinet in my home or office. This laptop utilises two-part verification for all external purposes (enhanced security measure), and has a password protected account dedicated to my therapy work. I am the sole user of this laptop.
If you desire additional security with emails, I have a proton email account I am happy to use. Otherwise I will use my usual work account – [email protected] – which is only accessed on this device.
Should we use telephone or video calls for our work, there will be a record of when the calls were made, but no information about what is discussed will be recorded or saved by me. If we use email, then our correspondence will be stored within my and your email clients or accounts.
Paper
I will make paper notes during our sessions, identified only by your first name. These will be kept in a locked filing cabinet in my office when not in active use.
Website
None of your information is stored on my website.
How I may share your personal information
Everything we discuss is confidential, unless you share with me your intention to cause harm to another person or organisation, or engage in activities such as terrorism, money laundering, or trafficking. I may be legally required to inform an authority without seeking your permission. In such a situation, I may also be required to share your personal information without your knowledge.
Other exceptions are shown below.
Supervision
All counsellors and therapists are required to attend monthly supervision with another therapist who is qualified in supervision (a supervisor), and who adheres to the same ethics and confidentiality requirements as all counsellors.
The supervision process is to ensure the highest standards in my practice. It is about how I work with you. In order to protect your privacy, my supervisor will not know you personally or professionally. I will refer to you only by your first name, and I may refer to your information verbally when it’s helpful to my professional practice and to how I can best support you. None of the content of these conversations are recorded, though I may make paper notes for my own use.
Therapeutic Will
Your name and contact details will be shared with my Therapeutic Executor. This is so that should I die unexpectedly while you are still in therapy with me, you will be contacted and offered alternative support.
Emergencies
With your consent wherever possible, if you or your health are at risk, I may share your contact information with an emergency healthcare service (e.g. Mental Health Crisis Team).
If you share with me your intention to cause harm to another person or organisation (e.g. terrorism, drug trafficking, money laundering), I may be legally required to inform an authority without seeking your permission. In such a situation, I may also be required to share your personal information without your knowledge.
How long do I hold your information?
I will store your session information (written or electronic) for up to seven years past the end of our working together. This is so that I have a reference of our work in situations such as you returning to supervision with me. After this time has passed, I will shred all information.
Your rights
You have the following rights:
• To know what information I hold about you (outlined on this page).
• To see the information I hold about you (free of charge for the initial request).
• To amend any inaccurate or incomplete personal information I hold about you.
• To withdraw consent to me using your personal information.
• To request that I delete any personal information I hold about you (though I can decline if the information is needed for me to practice lawfully and competently).
You can complain to the ICO if you are unhappy with how I have used your data. Please see below for contact information.
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF // 0303 123 1113
Please note
When you read through your contract and my GDPR policy, please ask me anything you are not sure about. Agreeing to the contract confirms that you agree to the terms of this GDPR statement and to the terms of the contract.
Disclaimer
This document outlines what I have done to ensure the confidentiality of your data and personal information, according to legal requirements. However, it is important to be aware that I do not have control over external software, apps or service providers, including those that you use. As such, it is important that you are happy with the services you use at your end. In addition, there are sometimes rare and unforeseen data breaches over which I have no control, such as hacking incidents.