Privacy Statement and Data Protection Agreement

Lucy Sands, of Sands Counselling & Psychotherapy prioritises the duty to protect the confidentiality of data shared by clients. The General Data Protection Regulation (GDPR) and Data Protection Act 2018 (DPA 2018) provide a legal framework for lawful information sharing. Any decision made to share confidential information must have a lawful basis, be necessary and justified and proportionate with regard to the Human Rights Act (1998) (JAPAN principles Justified, Authorised, Proportionate, Auditable and Necessary). 

Lucy Sands of Sands Counselling & Psychotherapy provides accurate and transparent information to all clients regarding data storing and sharing, via the Sands Counselling & Psychotherapy Privacy Statement and Data Protection agreement. 

Lucy Sands of Sands Counselling & Psychotherapy is registered with the Information Commissioner’s Office (ICO). ICO Reference Number: ZB600184 

Before a client’s first assessment session they are electronically sent a copy of the Sands Counselling & Psychotherapy Privacy Statement and Data Protection agreement. This document advises clients of the arrangements in place for utilising, storing and destroying the data they provide. 

The circumstances in which information may be shared outside of Sands Counselling & Psychotherapy are outlined to clients in their first session. Clients are advised of the need and rationale to breach confidentiality and share information externally. 

Clients are advised that Sands Counselling & Psychotherapy does not need client consent to share information externally, in instances where the client or a third party is at high risk of serious harm. 

 What data do I keep and why do I need it? 

 All of the following information is kept in an electronic folder within a password protected software system that requires a 2-step verification code to gain access. Each folder is kept under an identifying client code (no names). Lucy Sands of Sands Counselling and Psychotherapy is the only person that has access to this information. Lucy Sands’ mobile phone, which stores a client’s contact number and email address, is also secure, only openable by passcode or facial recognition. 

Personal Details 

Name, Address and Date of Birth – This is basic information to get to know you and is required for Professional Liability insurance as well as the requirements outlined by the BACP. 

Email address and phone number – This information is required to make contact regarding session arrangements. All Google Meets video calls require an email address. 

Medical Details – Information about your mental health history, physical medical conditions and current prescribed medications may help inform treatment plans. 

Emergency Details 

Next of Kin and Doctors details – Should Lucy Sands of Sands Counselling and Psychotherapy become concerned that you are at risk, she may contact your next of kin or doctor to keep you safe after a session. Wherever possible this will be discussed with you in advance. 

Notes 

Session Notes - These brief notes enable Lucy Sands of Sands Counselling and Psychotherapy to track client work. 

Payment Information 

Banking transactions may be viewed by employees of the bank, my accountant and tax officers (HMRC). When payment is made via BACS, your account name or reference (or the name of the person who is paying) may show up on my online or paper bank statements. 

Will I share your data? Who with and for what purpose? 

It is very unlikely that Lucy Sands of Sands Counselling and Psychotherapy will share your data. Lucy Sands will not sell it on, or use it for unethical reasons. 

Lucy Sands of Sands Counselling and Psychotherapy is required to be in clinical supervision. In supervision great care is taken to preserve client anonymity. 

Confidentiality is of utmost importance to the therapeutic relationship. Everything that is discussed during sessions is kept in the strictest of confidence. However, in exceptional circumstances confidentiality may have to be broken without the client’s consent. 

When could your data be shared? 

Lucy Sands of Sands Counselling and Psychotherapy will have to share sessions notes if they are subpoenaed by court. 

If you or a third party discussed during the session is at serious risk of harm. In this instance information may have to be passed to your next of kin, doctor, or the police. This can be carried out with or without your consent. 

In extreme cases, where Lucy Sands of Sands Counselling and Psychotherapy is legally compelled to breach confidentiality by statutory law, and inform relevant authorities about murder, rape, treason, kidnapping, terrorist activities, drug trafficking, abuse of a child, abuse of a vulnerable adult, crimes involving substantial financial gains or loss and any other serious crimes. 

Clinical Executor 

In the unfortunate event I can no longer work with you (due to ill health or death) my appointed clinical executor will have access to your phone number and email address to make contact. 

How long is your data stored for? 

Lucy Sands of Sands Counselling and Psychotherapy will keep the personal information outlined in this document for 7 years (from the date of your last session) for insurance purposes. During this time your data will be stored securely as described above. You have the right to view and edit the information stored about you. After 7 years all information is destroyed. 

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