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Privacy Notice

Privacy notice

In order to provide you with the best service possible we need to hold your personal contact details and, in some cases, records of your therapy sessions. This privacy notice tells you what we will do with your personal information from initial point of contact through to after therapy has ended. Here at Enfys Therapeutic Services, your privacy is very important to us and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to us. We 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. We also adhere to the ethical guidelines regarding protecting client privacy and confidentiality set by the British Association for Counselling and Psychotherapy (BACP).

 

Our lawful basis for holding and using your personal information

The GDPR states that we must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which we process your data. If you have had therapy with one of our therapists and it has now ended, they will use legitimate interest as a lawful basis for holding and using your personal information. If you are currently having therapy or if you are in contact with us to consider therapy, we will process your personal data where it is necessary for the performance of our contract. The GDPR also makes sure that your therapist looks after any sensitive personal information that you may disclose to them appropriately. This type of information is called ‘special category personal information’. The lawful basis for your therapist to process any special categories of personal information is that it is for the provision of health treatment (in this case therapy sessions) and necessary for a contract with a health professional (in this case, a contract between your therapist and you).

 

How the therapist will use your information at Enfys Therapeutic Services

We will never use your personal data for any purposes other than the administration of the therapy service that we are providing to you i.e. to arrange, cancel and rearrange appointments. We will only retain your personal information for as long as is necessary. This is in line with guidance from the Information Commissioner’s Office.

 

Initial contact

When you contact Enfys to book your first appointment, one of the coordinators will collect some brief information to process your enquiry. This will include your name and a contact method, for example an email address or phone number. This information is requested so that you could be informed if your therapist was unable to attend an appointment due to unforeseen circumstances. If you do not want to be contacted under any circumstances you do not need to provide a contact method. Alternatively, if another organisation, for example, your workplace or GP, sends your details when making a referral or a relative may give us your details when making an enquiry on your behalf. If an enquiry is made and you decide not to proceed, we will ensure that all of your personal data is deleted within one month. If you would like me to delete this information sooner, please let us know.

While you are accessing therapy

Your email address or phone number will be used to provide you with written confirmation of your appointment times if you have given consent for this. Your email address and telephone number will only be used to contact you regarding appointment times unless you have agreed that your therapist will also use your email address to email you information that is relevant to your therapy sessions.
At the beginning of your first appointment your therapist will ask you to complete a personal details form containing your name, address, date of birth, contact information and also contact information for your GP. Please be aware that your therapist will not routinely contact your GP to inform your GP of your attendance as your attendance is confidential. To fulfil their duty of care towards you while also maintaining your confidentiality, your therapist will only contact your GP if it is necessary and should these circumstances arise they would discuss this with you wherever possible before contacting your GP.

Each therapist using Enfys Therapeutic Services will have their own way of storing this information. This will either be in a locked filing cabinet that can only be accessed by your therapist, or one of the managers. Alternatively on a password-protected system on their laptops with anti-virus software. The therapist will explain which method they use during your first initial contact

Rest assured that what is said in your sessions will be kept confidential. All therapists using Enfys Therapeutic Services are members of the British Association of Counselling & Psychotherapy (BACP) and they abide by their professional code of ethics. Confidentiality will only be broken if there are legal or ethical obligations to disclose, for example, if you disclose abuse/neglect of a child or vulnerable adult, or say something else that implies serious harm to yourself or others, or if a court of law requires me to disclose information.
In the event that confidentiality must be broken, your therapist will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
Therapists are required to have regular supervision support so they may discuss their work with you, with their supervisor. This would be done without identifying you and the supervisor is also a counsellor/therapist who abides by the BACP’s code of ethics regarding confidentiality.

Your therapist may keep brief notes of your therapy sessions for the purpose of assisting your work together. The notes help to keep track of the issues that you and your therapist are working on and they are for the use of the therapist only. The notes will not include any personal details that could be used to identify you, and they are stored securely by the method used by your individual therapist as explained in your first initial contact. Only your therapist will have access to these. Your therapy notes are stored separately to your personal details form.

After therapy has ended

There are reasons why therapists are required to keep records after therapy has ended. For example, in the case of financial transactions, personal information must be retained for as long as legally required in respect of tax or accounting purposes. Retaining your therapy notes ensures that the therapist can continue to offer you an efficient service if you make contact after therapy has ended. Your therapy notes do not include any personal details that could be used to identify you and continue to be stored securely as described by your therapist for seven years after therapy has ended. This time frame adheres with current industry guidelines. Seven years after therapy has ended your therapy notes will be confidentially destroyed.

Your personal details form is confidentially destroyed on ending your therapy sessions. Please note that your therapist will need to keep a record of your name, date of birth and your client reference number for seven years after therapy ends. Your client reference number corresponds with a client reference number on your therapy notes and therefore enables them to identify your therapy notes if necessary.

 

Third-party recipients of personal data

Here at Enfys Therapeutic Services, we share a limited amount of personal data with third parties in order to provide therapy services to you and to fulfil legal obligations in respect of tax and accounting purposes. For example, our accountant is permitted access to our invoices.
If your appointments are paid for or arranged via a third party, for example, your employer the only information shared with the third party is your dates of attendance and non-attendance for invoicing and payment purposes. Details about what is discussed in your appointments will remain confidential and can only be shared if you give your written consent to do so.

If you contact Enfys Therapeutic Services to book an appointment and our therapists is unavailable to work with you, with your consent, we can pass on your contact details to one of our associate therapists for them to arrange an appointment with you at Enfys. All therapists that use Enfys have been vetted to ensure they are appropriately qualified, insured to practice as a therapist, they are DBS checked and are members of a professional body.

 

Data security

At Enfys Therapeutic Services we take the security of the data that we hold about you very seriously. The email account we have is password protected and mobile phones and laptops used to respond to your emails are password protected and have anti-virus software. Only the coordinators at Enfys will have access to the email account when you first make contact with us. Any email correspondence will be deleted within one month if it is not necessary to keep it. If it is necessary to retain the information it will be kept securely with the other information held.

 

Website Visitors

By accessing the website, you are consenting to the information collection and use practices described in this privacy notice. Should you choose to contact me using the contact form on the website none of the data that you supply will be stored by the website or passed to any third-party data processors. Instead, the data will be collated into an email and sent to me over the Simple Mail Transfer Protocol (SMTP). SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted before being sent across the internet. The email content is then decrypted by local computers and devices.

The website uses cookies and Google Analytics. Almost all websites use cookies which are small files that get put on your computer by websites as you surf them. These cookies can store lots of information which can have privacy implications. Google Analytics is a service provided by Google that gathers anonymous data on how people are using websites and then provides visitor statistics, details of page views etc. This service is used by many website owners as the data helps website owners to improve their websites.

 

Your rights

Under GDPR, 2018 guidelines you have the following rights: The right to request access to the personal information that is stored and processed about you. You can ask for corrections to be made to the information held or for your personal information to be deleted. You can also ask your therapist to restrict the processing of your personal information or to object to the processing of it altogether in some circumstances. You can read more about your rights at ico.org.uk/your-data-matters.

If you would like to make a request relating to any of the rights above, please send a request in writing by emailing enquiries@enfystherapeuticservices.co.uk. Please be aware that in certain situations your therapist may be unable to comply with the above requests. For example, if compelled to retain the records by a court of law. Please also be aware that there may be a charge for complying with a request if it is deemed to be excessive in nature.

 

Complaints

If you have a complaint about how we handle your personal data, please do not hesitate to get in touch by email at enquiries@enfystherapeuticservices.co.uk. If you want to make a formal complaint about the way we 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 ico.org.uk/make-a-complaint.

Changes to the privacy notice

This privacy notice may be updated from time to time, so please check occasionally for any updates.

 

Please note, that here at Enfys Therapeutic Services we have our own therapists as well as associate therapists that use our premises, and we pass on referrals to them. This Privacy Notice applies to the therapists at Enfys, and although all therapists using our premises will be expected to abide by our privacy notice. Each therapist may have their own that they use. If this is different from ours they will explain this in your first initial contact with them. All therapists who operate out of Enfys will be vetted to ensure they are appropriately qualified, they are insured to practice as a therapist, they are DBS checked and a member of a professional body.