Privacy Notice

What information I collect, use, and why

We collect or use the following information to provide patient care, services:

• Name and contact details

• Gender

• Pronoun preferences

• Next of Kin details including any support networks

• Emergency contact details

• Health information (including medical conditions, allergies, medical requirements and medical history)

• Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)

• Payment details (including card or bank information for transfers and direct debits)

• Insurance policy details

We also collect the following information to provide patient care, services:

• Racial or ethnic origin

• Religious or philosophical beliefs

• Health information

• Sex life information

• Sexual orientation information

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.

• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.

• Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.

• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.

• Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.

• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.

• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

The lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide patient care are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legitimate interest:

• Keeping records of assessments and therapy sessions helps me to remember what has been discussed. This can inform what is discussed in supervision and helps to create treatment plans. This ensures you receive ethical and appropriate care. 

• Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Where we get personal information from

• Directly from you

• Insurance companies

How long we keep information

The BABCP advises that private client records should be kept for 7 years after the last session. Notes are destroyed as soon as this period has elapsed.

Who we share information with

Others we share personal information with:

• Organisations we need to share information with for safeguarding reasons

• Non-identifiable information is shared with my supervisor.

Duty of confidentiality

We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:

• you’ve provided us with your consent;

• we have a legal requirement (including court orders) to collect, share or use the data;

• on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);

• If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or

• If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint