At NW Counselling Hub (NWCH) we understand how important your privacy is. We take care to maintain your confidentiality in accordance with current data protection laws General Data Protection regulation (GDPR, 2018) and the ethical guidelines of the British Association for Counselling and Psychotherapy (BACP) and the National Counselling Society (NCS). These guidelines have been set up to protect your confidential material and ensure that your therapist always conducts themselves with professionalism and integrity. To provide you with the best service possible, we will hold your personal contact details and records of your therapy sessions. Please find below important information about how this information will be held and used.
Your personal information
At the point of booking your initial appointment with us we will complete an assessment form, where we will ask for your personal contact information, for example your name, address, email address and telephone number as well as details of the issues you are looking for help with. And your contact information, date of birth, contact information for your GP and elected Emergency Contact. Your contact information is stored securely in a password protected document and in our secure cloud system – SharePoint. This information can only be accessed by the management team and your therapist. Your notes are stored in a locked cabinet and will only be accessed by our admin team or your therapist.
This personal information will be held for the duration of your therapy after which it will be held for seven years. Please note that we will need to keep these records for seven years after the end of your therapy, so that we can respond effectively to any potential requests regarding your clinical notes and treatment. If there are any safeguarding issues raised in your therapy these notes will be kept for seventy-five years, which is in line with the children’s act 2004 and the safeguarding vulnerable groups act 2006.
We will never pass on your contact details to any third-party organisations for the purposes of sales, marketing or research and will never use your personal data for any purposes other than the administration of the counselling service we are providing to you i.e. to arrange, cancel and rearrange appointments and collect payment for sessions.
If you ask us to refer you to another organisation for further support, we will share with that organisation your assessment form. We will inform you of this.
If you are seeking funding for your therapy sessions through a third party in some cases, we may share your assessment form. Your funding application is stored as described above.
When you make an online booking or enquiry through 10to8, (our online booking plug in) and Stripe (our online payment system) send our office emails which respectively provide the booking details and confirm payment. These emails contain your name and the contact details that you provided at the point of booking. These emails are deleted from our email account and the payment record is stored in our accountancy software Xero. The HMRC requires that we retain this information for 6 years after the end of the financial year. 10to8 stores your booking entry in our outlook calendar. These entries contain the contact information and any notes that you provided at the point of booking but will not contain the information on your assessment. The 10to8 calendar is stored securely on our server and the entries in our outlook calendar are anonymised with your client code.
Your payment details
All payments made through our website nwcounsellinghub.co.uk or through your invoice (Xero accountancy software) are made through the Secure Xero and Stripe servers. Our website therefore does not hold your payment information. Where you have made payment for your session over the phone, our admin team will never keep a record of your card details. Your information is inputted directly into the card machine (Square) and no written record, apart from the merchant copy receipt, will be taken.
Your therapy sessions
Everything that you discuss with your therapist is confidential.
Our counsellors may have to pass on any information to the relevant authorities in cases where human safety is concerned including the following cases:
1. If you threaten harm to yourself or to another person
2. If we believe a child or protected adult is at risk of harm or abuse
3. If the courts instruct us to give information
4. If you share information about a proposed act of terrorism or another illegal act
We will always endeavour to speak to you about this first.
Your therapist discusses their clinical work with a supervisor. This is to ensure that they are offering you the best service possible. These conversations are bound by confidentiality and you will only be referred to by your first name and/or client code. Your therapist will also keep notes of each session. These are anonymised and are stored in a locked filing cabinet. These notes are for your therapist’s use only and help them to keep a track of everything that is being discussed. In line with industry guidelines, these notes must be kept securely for seven years after your therapy comes to an end. After this time, they will be confidentially destroyed. If there are any safeguarding issues raised in your therapy these notes will be kept for seventy-five years, which is in line with the children’s act 2004 and the safeguarding vulnerable groups act 2006.
If your sessions are paid for or arranged via a third party, (e.g. your employer, a friend, or a family member), other than payment requests, invoices or receipts your counselling information will not be shared. Details about what is discussed in your sessions will remain confidential between you and your therapist. Any other information can only be shared if you give us your written consent to do so.
Your communications with us
All of our email accounts use the secure Office 365 server and are backed up by our IT server Octagon Technology and are password protected. If you send an email to your therapist’s email address, only they will have access to it. All phones, tablets and laptops used to respond to your emails are encrypted, fully protected with anti-virus software and password protected.
We will only use your email address and telephone number to contact you about your appointments. Your therapist may also contact you directly via email in order to share information with you that is pertinent to your therapeutic process. Your phone number and email address will also be used to issue appointment reminders via text message and email.
Any personal data retained by our service or your therapist is kept in accordance with the GDPR, 2018.
Under these guidelines you have the following rights:
1. The right to request access to your data
You can request to view the information that we hold about you (contact details, appointment logs etc.) at any time. If during therapy you would like to see your session notes, please make this request to your therapist directly. Should you require a copy of your notes after your therapy has come to an end you can make this request by emailing our office at email@example.com or calling us on 01522 253809, or in writing to, NWCH, Unit 10, Allenby Business Park, Lincoln, LN3 4NL.
2. The right of rectification
At any point during your time at NWCH or during the seven years thereafter, while we retain your records, you have the right to request amendments to your contact details or session notes. This right can be exercised either by speaking directly to your therapist or by contacting our office.
3. The right to be forgotten
You can request that we delete and confidentially destroy the information that we hold about you and your sessions at any time. This request can be made by contacting the management team. We will destroy any identifying details we hold about you, such as name address etc. We have to keep your client notes for 7 years or 75 years if any safeguarding issues are mentioned in your sessions.
Instances where we would not be able to comply with your request are as follows:
a) It is necessary for us to retain these records in order to continue providing an effective service
b) We are compelled to retain these records by a Court of Law
c) We require these records in order to establish, exercise or defend legal claims
At the end of your initial consultation/first appointment you will be asked to sign a consent form stating that you understand and agree to our terms and conditions and the privacy agreement outlined above. In doing so you give NWCH and your therapist permission to store, access and use your personal contact details and session notes within the legitimate remit of providing a counselling service to you. You are entitled to withdraw this consent at any time and can do so by emailing our office at firstname.lastname@example.org
Breaches of data protection
In the event of any breach of our data protection policies, we will notify you and the Information Commissioner’s Office (ICO) within 72 hours and will seek to rectify this immediately.
Should you have any concerns about our data protection practices, you can raise these directly with your therapist and/or the management team. Or directly with the Data Protection Officer (DPO) Naomi Watkins. You can also notify the Information Commissioner’s Office. We are registered with ICO NW Counselling Hub CIC.