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.
Personal data is, as I understand it, information relating to a natural person (the data subject), who can be directly or indirectly identified by the use of that data; for example by their name, ID number, online identifier such as an email address or by postal address and telephone numbers.
This privacy notice tells you what I will do with your personal information from initial point of contact through to after your therapy 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
• Your data protection rights
I will update this privacy notice regularly to ensure it continues to comply with the latest regulations and best practice. This privacy notice was last amended on 11 March 2020.
2. About me
Joanna Wajszczuk, trading as On Therapy is registered as a data controller with the Information Commissioner’s Office (ICO) (ICO registered number ZA444808).
If you have any queries about this privacy notice or about any aspect of my data management, please contact the “data controller” at firstname.lastname@example.org
‘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.
3. 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 are contacting me to enquire about my therapy services and 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 that it is for provision of health treatment (in this case psychological therapy) and necessary for a contract with a health professional (in this case, a contract between me and you).
4. How I use your information
When you contact me with an enquiry about my therapy services, I will collect information to help me satisfy your enquiry. This will include your full name, contact number and email address. At a later stage and just before/during your first session, I will also ask you for home address, date of birth, your GP details and a name, telephone number and address for an emergency contact person and details about your private health insurance if applicable. Alternatively, your GP or other health professionals may send me your details when making a referral or a parent or 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 one year. If you would like me to delete this information sooner, just let me know.
While you are accessing psychological therapy
Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if I have a legal or ethical obligation, which conflicts with clinical confidentiality. For example, if I believe either yourself or someone else is at imminent risk from what you have disclosed to me. I will always try to speak to you about this first unless there are safeguarding issues that prevent this.
I will keep a record of your personal details to help your therapy run smoothly. These details are kept securely on my personal computer and are not shared with any third party.
I will keep written notes of each therapy session, these are kept in a secure and locked cabinet at my home address. The purpose of keeping these notes is solely for my own use and record of the work we have done, in case I will need to refer to this at a later stage.
For security reasons, I will regularly, and within 6 months, delete text messages from or to you. If there is relevant information contained in a text message I will make a note of these in your written notes. Likewise, any email correspondence will be deleted after one year if it is not important. If necessary I will keep a written copy in your written notes.
I may refer to our work in my (professional and peer) supervision, that is a requirement of my professional practice. I will not disclose any personally identifiable information about you during supervision, nor share any personal data or written notes with any supervisor.
After your psychological therapy has ended
Once your therapy has ended, your records will be kept for seven 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.
5. Third-party recipients of personal data
I will not share your personal data with any third parties.
All professional supervision I receive is for the purpose of ensuring that I provide safe and efficient therapy to yourself.
I will not share copies of my notes or your name or other identifiable material with any of my supervisors (peer or professional). However, I may share verbally some details of the issues that you bring to our work and discuss these and how I am working with you in supervision, in confidence. I will endeavour to keep all identifiable information about you from the content of my supervision work.
6. 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 me to delete your personal information, to limit how I use your personal information, or to stop processing your personal information. You also 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.
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 its, 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.
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 details of your request in writing addressing it to email@example.com. I will respond to your request with the relevant data within 30 days in an electronic format, if possible.
If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by email to the contact details given above.
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.
7. 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. I regularly update computer operating systems and software in order to be up to date with necessary security updates and keep written notes in a locked filing cabinet. The computer, which is used to store your personal data is furthermore password protect
8. Visitors to my website
I use legitimate interests as my lawful basis for collecting, holding and using your personal information when you visit my website.
8.1.1 On Therapy understands that your privacy is important to you and that you care about how your personal data is used and shared online. I, Joanna Wajszczuk, owner of On Therapy, respect and value the privacy of everyone who visits this website, ontherapy.co.uk, and will only collect and use personal data in ways that are described here, and in a manner that is consistent with my obligations and your rights under the law.
8.1.2 The General Data Protection Regulation 2016/679 (GDPR) is a regulation in EU law on data protection and privacy for all individuals within the European Union and the European Economic Area. It has a particular emphasis on the processing of personal data by organisations including sole traders. Personal data is, as I understand it, information relating to a natural person (the data subject), who can be directly or indirectly identified by the use of that data; for example by their name, ID number, online identifier such as an email address or by postal address and telephone numbers.
8.1.3 As a sole trader (On Therapy Joanna Wajszczuk) I believe to be in keeping with the regulation I must inform you as a user of my website how your data (personal data) will be used.
8.2 Information about me
8.2.1 This website is owned and operated by me.
8.2.3 The Data Protection Officer is Joanna Wajszczuk and can be contacted by email at firstname.lastname@example.org.
8.3 What does this notice cover?
This Privacy Notice applies only to your use of this website – ontherapy.co.uk. This website may contain links to other websites. Please note that I have no control over how your data is collected, stored, or used by other websites and I advise you to check the privacy policies of any such websites before providing any data to them.
8.4 What data do I collect?
8.4.2 date of birth;
8.4.4 business/company name;
8.4.5 job title;
8.4.7 contact information such as email addresses and telephone numbers;
8.4.8 demographic information such as address and postcode;
8.4.9 banking details for payments;
8.4.10 General Practitioner details;
8.4.12 Medical history;
8.5 How do I use your data?
For details about how I use your data collected via this website, please refer to section “4. How I use your information” above.
8.6 How can you control your data?
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receive.
8.7 Your right to withhold information
8.7.1 You may access certain areas of this website without providing any data at all.
8.8 Collecting standard internet log information and details of visitor behaviour patterns
Further information concerning the terms and conditions of use and data privacy can be found at the Google Analytics Terms of Service or at the Google Analytics Privacy Overview. Please note that on this website, Google Analytics is supplemented by “gat._anonymizeIp();” to ensure an anonymized collection of IP addresses (IP masking).
8.8.3 No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.