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 only used for the purpose for which it was given to me. This privacy policy describes my policy and procedures on the collection, use and disclosure of your information when you use my service and tells you about your privacy rights and how the law protects you. 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. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. I do this now by requesting that you read the information provided at https://knowyourprivacyrights.org

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

• Why I am able to process your information and for 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

‘Data controller’ is the term used to describe the person/organisation that collects, stores and has responsibility for people’s personal data. In this instance, the data controller is myself. I am registered with the Information Commissioner’s Office and my registration number is ZB095172. My email is: tiggy.wilson@protonmail.com. I am happy to chat through any questions you may have about my data protection policy therefore please feel free to make contact if you wish to chat through anything that you don’t understand or want more clarity on.

Information I process because I have a contractual agreement with you

When you agree to the terms and conditions within my Agreement and Assessment for counselling services a contract is formed between you and I. In order to carry out my obligations under that contract I have to process the information you give me, including your personal information. I may use it in order to verify your identity for security purposes and provide you with my service as a counsellor. I process this information on the basis there is an agreement between us, or that you have requested that I use the information before we enter into a legal agreement. I may also combine this information in a general way and use it to monitor my performance with respect to the counselling service that I offer. If I use it for this purpose, you as an individual will not be personally identifiable.

I shall continue to process this information until the agreement between us ends or is terminated by either party under the terms of the agreement. If you decide you do not wish to proceed, I will ensure all your personal data is deleted from my computer system within one month. If you would like me to delete this information sooner, please let me know by emailing me at tiggy.wilson@protonmail.com

Information I process with your consent

Through actions when otherwise there is no formal agreement made between us, for instance such as when you browse my website or ask me to provide you more information about my service, you provide me with your consent to process information that may be personal information. Sometimes you might give your consent implicitly, such as when you send me a message by email to which you would expect me to reply. Except where you have consented to my use of your information for a specific purpose, I do not use your information in any way that would identify you personally. I continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You may withdraw your consent at any time by instructing me to do so at tiggy.wilson@protonmail.com

Initial contact

When you contact me with an enquiry about my counselling services I will collect information to help me satisfy your enquiry. This will include your name, date of birth, contact number, contact email and home address.

If you decide not to proceed I will ensure all your personal data is deleted within a month of your initial enquiry. If you would like me to delete this information sooner just let me know.

While you are accessing counselling, everything you discuss with me is confidential.

That confidentiality will only be broken:

• If you disclose, or I believe you are at risk of serious harm to yourself or others, and where I am concerned about your own, or someone else’s safety. If you disclose during the online counselling work, that you have suicidal ideation, intent, or plans, and are considering serious self-harm, I will discuss the appropriate support and services with you. This could include me contacting your emergency contact, GP, crisis team or the emergency services

• If you disclose or inform me of any form of abuse or neglect that affects a child or vulnerable adult

• If you disclose involvement in or knowledge of an act of terrorism, money laundering, or drug trafficking. This is a legal obligation and therefore has to be reported

• If I receive a subpoena from the court of law (including a request to see your counselling session notes)

I will always try to speak to you first about any of the above, unless there are safeguarding issues that prevent me from doing this

I will keep a record of your personal details to help my counselling service run smoothly. These details are kept securely on a password and encrypted computer and are not shared with a third party. I keep brief written notes of sessions which I anonymise so that there is no personal information attached and I keep these in a locked cabinet with the key kept separately. For security reasons I do not retain text messages for more than one month. If there is relevant information contained in a text message this will be transferred to my securely kept, anonymised short notes. When we have finished working together, I will erase electronic copies of your data & correspondence within one month. Any written/printed record of data relating to our sessions will be kept securely for up to seven years past the end of our time working together. This is so that I have a reference of our work for such situations as you returning to counselling in the future or if they are required for legal reasons. After this time has passed, I will securely destroy your written/printed data.

Sending a message via my website

When you contact me, whether by telephone, through my website or by email, I collect the data you have given to me in order to reply to you with the information you need. I keep personally identifiable information associated with your message, such as your name and email address on a password protected, encrypted computer so as to be able to track my communications with you in order to provide a high quality service.

I use a dedicated smartphone which is password protected for counselling clients for use during our work and for use in case of technology breakdown or emergencies. Your mobile number will be allocated an individual code in my contact list in order to retain anonymity during our work together.

Sending an enquiry via my website

My website is hosted by Squarespace Inc. When making an initial enquiry via my website, you provide your personal details such as name and contact details which Squarespace collect and then transfer to me. It then becomes my responsibility to securely collect and process personal information about you under my own privacy policy. Squarespace’s privacy policy can be found at https://squarespace.com/privacy. Their website traffic is encrypted via SSL providing a secure end to end connection for both me and all my clients. Squarespace implements and maintains technical and organisational security measures to protect company and customer assets and data. Their data centre and cloud service providers use an array of security equipment, techniques and procedures which control, monitor, and record access to the facilities. Squarespace has also implemented solutions designed to protect against and mitigate effects of DDoS attacks.

Your Rights

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 https://ico.org.uk/your-data-matters.

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

Use of Information

Cookies

A cookie is a small text file that is placed on your computer's hard drive by your web browser when you visit any website, providing you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved. Squarespace uses some necessary cookies because they allow visitors to navigate and use key features on your site. You can instruct your browser to refuse all cookies, or to indicate when a cookie is being sent, but if you do not accept cookies, then you may be unable to use parts of my service.

Information I obtain from third parties

I do not disclose your personal information to any third party (except as set out in this notice).

Access to your personal information

At any time you may review correct, or update personally identifiable information that I hold about you, by asking me to update your information. For a copy of any information that is not provided on my website please send me a request at tiggy.wilson@protonmail.com After receiving the request, I will tell you when I expect to provide you with the information, and whether I require any fee for providing it to you.

Verification of your information

When I receive any request to access, edit or delete personal identifiable information I shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Encryption of data sent between us

I use Secure Sockets Layer (SSL) certificates to verify my identity to your browser and to encrypt any data you provide to me. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

How you can complain

If you are not happy with my privacy policy or if have any complaint then you should inform me by email at tiggy.wilson@protonmail.com If a dispute is not settled then I hope you will agree to attempt to resolve it by engaging with me in a process of mediation. If you are in any way dissatisfied about how I process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done via the following website: https://ico.org.uk/concerns/.

Retention period for personal data

Except as otherwise mentioned in this privacy notice, I keep your personal information only for as long as required by me:

• to provide you with the services you have requested

• to comply with other law, including for the period demanded by our tax authorities

• to support a claim or defence in court

Compliance with the law

My privacy policy has been compiled so as to comply with the law of the country or legal jurisdiction in which I aim to do business. Ultimately, however, it is your personal choice as to whether you wish to use my website.

Review of this privacy policy

I may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on my website on the day you use my website. I advise you to print a copy for your records.

If you have any questions regarding my privacy policy, please get in touch.