Moor Counselling Practice Privacy Notice

General Principles

• I am committed to ethical practice and understand that confidentiality is a vital part of this.
• I am registered with the Information Commissioner’s Office (ICO) as a Data Controller
• (Dr Philippa Moorhead, ICO Reg No  00010979914)
•  and I am committed to complying with the relevant legal frameworks.

Your Rights under GDPR.

• The right to be informed (about collection and use of your data).
• The right to access (data I hold about you).
• The right of rectification (correction or completion of inaccurate data).
• The right of erasure (the right to be forgotten- in certain circumstances).
• The right to restrict data processing (in certain circumstances).
• The right to data portability.
• The right to object to data processing (in certain circumstances).
• Rights in relation to automated decision making.
• The right to withdraw consent.
• The right to complain to the ICO.

What data do I collect?

• If you should become a counselling client, I collect the following data:
• Name and date of birth – so that I can identify you.
• Email, phone number, address – so that I can contact you about our sessions.
• GP details/Emergency contact no. – so that I can keep our work together safe and ethical (further details in my Working Agreement).
• Session Notes – are brief and handwritten, to aid my memory of what we have talked about.
• Payment Information – if you pay my by BACS (my preferred option) your account information is held by my bank.
• Emails between us.
• Invoices and Receipts.

Will I share your data?

• You data is only used by me in relation to my counselling service. It is not used for marketing purposes, nor is it sold on to third parties.
• There are a limited number of circumstances where it may be necessary to share your data:
• Audit/Accounting purposes. I may need to share bank transactions details with HMRC or my accountants. These may also be viewed by bank employees.
• Clinical Will. If I become significantly unwell or incapacitated, a designated fellow counsellor has instructions how to contact my clients to inform them of the situation and if necessary destroy all records.
• Serious risk of harm to you or to others (further details in my Working Agreement).
• Legal Requirements. If ordered by a court of law.

How is my data stored?

• Your phone number (and any texts) are stored on my mobile phone.
• Emails are received on my laptop and my mobile phone.
• Devices are password protected. (NB Email is not secure unless encryption is used).
• Anonymised session notes are kept in a locked filing cabinet inaccessible to others.
• Signed Working Agreement forms are locked away, and the Identifying Key to connect notes to ID is kept in another location.

 How long do I keep your data for and how will I dispose of it?

• If you do not decide to book an appointment with me, your details are deleted.
• Texts and emails are deleted when no longer needed, and within 3 months of our finishing work together.
• Payment details are automatically logged and stored by my bank, and for tax purposes I need to retain these for 7 years, and these will be further retained by the Bank according to their own code of practice.
• My insurers recommend that I keep notes for 7 years after our last session together.
• Thereafter, information will be disposed of securely and confidentially.

What would happen if there was a data breach involving my data?

A data breach means an accidental or deliberate breach of security leading to the destruction, loss, alteration, unauthorised disclosure of, or access to, personal data.    I undertake to record any data breaches I am aware of, and to promptly inform the subject of the data, the ICO and other relevant authorities, where appropriate.

If you have any questions about the above you can contact me in my capacity as Data Controller:

Dr. Philippa Moorhead

Moor Counselling

You have the right to lodge a complaint with the National Counselling and Psychotherapy Society ( NCPS) the professional body with which I am accredited and/or the Information Commissioner’s Office (ICO).

This policy is kept under review: 25th April 2024