Privacy Policy

Effective date: 15 October 2023

1. Introduction

Your privacy is paramount to us, both during therapeutic sessions and beyond. As counsellors, we are registered with the ICO to ensure the safekeeping of records, in compliance with the EU General Data Protection Regulation (GDPR) and the ethical guidelines of my professional bodies (BACP and NCPS).

2. Agreement

This GDPR agreement sets out how we collect any personal data collect from you, or that you provide to us, will be stored and processed confidentially, in accordance with the GDPR, 2018.

Any personal data we collect from you, or that you provide to us will be stored in line with the GDPR, 2018. Any session notes we take are very brief and anonymised, using only your initials, and are securely password-protected. Further, all data, whether on a computer or other devices, is safeguarded with passwords and biometric access. Additionally, any signed contracts are securely stored in a lockable cabinet, protected with a safety code. Your information will never be shared with third parties for sales, research, or marketing purposes.

It is important that the personal information we hold about you is accurate and current. Please keep your counsellor informed if your personal information changes during therapy.

3. Data Collection

To work ethically and provide the best service, we will need to collect, store, and use the following personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
  • Date of birth.
  • Emergency contact number, including GP contact information.
  • Bank account details.
  • Start and end date.
  • Number of sessions, brief notes, mental health questionnaires, discharge forms, evaluation forms and exercise sheets.

4. Data Retention

Text messages are deleted immediately and we won’t store your number on any phone. Emails are only kept if relevant to our ongoing work together. We will retain brief sessions notes whilst we are working together.

After therapy has finished, we will retain these documents for a further five years in case you decide to return to therapy with our counsellors. This is also a requirement of our indemnity insurance, after which time we destroy all information and contact details.

5. Disclosure

In the event of incapacity or death of your counsellor, your personal contact information will be disclosed to the clinical executor of the counsellor's Professional Will, so that they can notify you. In the event of death, my executor will also destroy all contact information and notes stored on their computer.

Your counsellor may be under a duty to disclose or share your personal data in order to comply with any legal obligation. For example, if your counsellor is subpoenaed to court, or as a legal requirement such as safeguarding children or vulnerable adults, terrorism or money laundering.

As part of ethical practice and our counsellors' commitment to providing a professional service, all are attend supervision regularly. This is bound by a confidentiality contract (separate to this policy) and to protect your identity they only use the initial of your first name.

6. Your Rights

You are entitled to view, amend, or delete the personal information that we hold. All requests have a month to be carried out. 

7. Data Breaches

We have a legal obligation to report a data breach to you and the Informations Commissioners Office (ICO) within 72 hours.

8. Consent

Consent to the GDPR agreement is deemed accepted by your use and undertaking of the services of Tunbridge Wells Counselling Hub, or any of its counsellors, and constitutes your approval and acceptance of this agreement and you are consenting to their use, and storage of your personal information, you have disclosed to them, as detailed above. You have the right to withdraw your consent at any time.