Sarah Barnsbury Therapy

I am a therapist working in London, who helps people have better relationships with others, and themselves.

Introduction

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

• Why I am able to process your information and 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;

• Whether I intend to transfer it to another country;

• Whether I do automated decision-making or profiling, and

• Your data protection rights.

I am happy to chat through any questions you might have about my data protection policy and you can contact me via sarahbarnsbury@gmail.com. ‘Data controller’ is the term used to describe the person/ organisation that collects and stores and has responsibility for people’s personal data. I am the data controller for your personal data.

I am registered with the Information Commissioner’s Office under registration reference ZB718524, under the name Ms Sarah Barnsbury. My email address is: sarahbarnsbury@gmail.com

My lawful basis for holding and using your personal information

The GDPR states that I must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which I am processing your data. I have explained these below:

If you have had therapy with me and it has ended, I will continue to store your clinical records under my legitimate interests, which are:

  • maintaining professional clinical records
  • responding to any legal claims
  • meeting insurance and professional indemnity requirements

This is balanced against your rights and interests and does not override them. If you are currently having therapy or if you are in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of our contract. The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for processing special category data is Article 9(2)(h) UK GDPR: provision of health or social care or treatment and management of health or social care systems and services.

How I use your information

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, contact details, address, preferred pronouns, date of birth and GP details. Alternatively, your GP or other health professional may send me your details when making a referral or a parent or trusted individual may give me your details when making an enquiry on your behalf. If you decide not to proceed I will ensure all your personal data is deleted within six months. If you would like me to delete this information sooner, just let me know.

While you are accessing counselling

Rest assured that everything you discuss with me is confidential. That confidentiality may only be broken in the following circumstances: where there is a serious risk of harm to you or others and/or a safeguarding concern involving a child or vulnerable adult or in order to comply with any legal obligation (for example, if required to do so by a court order). I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.

I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely on my password protected laptop and phone and are not shared with any third party. I will keep written notes of each session, which are pseudonymised (using initials or a code rather than your full name) and kept in a password protected file that is stored in my private Dropbox Cloud account. Dropbox may store data outside the UK/EEA depending on infrastructure. I ensure appropriate safeguards are in place for any international data transfers, such as UK adequacy regulations or standard contractual clauses. For more details about Dropbox security, please see here: https://help.dropbox.com/security/how-security-works. For security reasons I do not retain text messages for more than 6 months. If there is relevant information contained in a text message I will save that to your pseudonymised and password protected file. Likewise, any email correspondence will be deleted after six months if it is not important. If necessary I will save it to your pseudonymised and password protected file.

After counselling has ended.

Once counselling has ended your records will be kept for 7 years from the end of our contact with each other and are then securely destroyed. Retention is based on professional insurance requirements and legitimate interests in maintaining clinical records. If you want me to delete your information sooner than this, please tell me.

Third party recipients of personal data

I sometimes share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks. In such cases I have carefully selected which partners I work with. I take great care to ensure that I have a contract with the third party that states what they are allowed to do with the data I share with them. I ensure that they do not use your information in any way other than the task for which they have been contracted. These third-party providers may process data outside the UK. Where this occurs, appropriate safeguards are in place to ensure compliance with UK GDPR.

Your rights

I try to be as open as I can be in terms of giving people access to their personal information. 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 also have the right to data portability and the right to restrict processing. You can read more about your rights at ico.org.uk/your-data-matters. If I do hold information about you:

  • I will give you a description of it and where it came from;
  • tell you why I am holding it;
  • tell you how long I will store your data and how I made this decision;
  • tell you who it could be disclosed to;
  • let you have a copy of the information in an intelligible form. You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you.

To make a request for any personal information I may hold about you, please put the request in writing addressing it to sarahbarnsbury@gmail.com.

Complaints

If you have a concern about how I handle your personal data please submit your complaint to sarahbarnsbury@gmail.com. I will acknowledge your complaint within 30 days of receipt. I will investigate and provide a full response without undue delay. I will keep you informed through the process. If you remain dissatisfied with my response, you may escalate your complaint to 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.

Visitors to my website

When someone visits my website, I use a third party service, WordPress, to collect standard internet log information and details of visitor behaviour patterns. This includes IP address, browser type, and usage data. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. I do not make, and do not allow WordPress to make, any attempt to find out the identities of those visiting my website. I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website. Where cookies are used, I will obtain consent where required under PECR. I use Google Analytics so that I can continually improve my service to you, Google Analytics collects pseudonymised usage data to help improve my website performance. You can read Google Analytics privacy notice here: https://policies.google.com/technologies/partner-sites. I use WordPress as the content management system for my website – find out about WordPress and data protection https://automattic.com/privacy-notice/. Like most websites we use cookies to help the site work more efficiently – find out about our use of cookies https://automattic.com/cookies/. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to my email.