Gestalt-counselling.co.uk is my website offering and promoting my face-to-face and on-line counselling services. “I”, “we”, “counsellor” or “us” or similar terms refer to me as the service provider, Roxana Wood. “You” or “your” or similar terms refer to you as a client.
You are entrusting me with some of your most personal and valuable information, including your personal health information. I take your privacy seriously and I am committed to safeguarding and protecting this information. I only collect the personal information required for the purposes of initial assessment and ensuring that my service is appropriate for your needs. In the case of online counselling, you may provide this information voluntarily in free-form text boxes on my website and/or through responses to a client questionnaire. This will be through a secure and encrypted third party platform. This information will assist me in offering a safe and more effective online counselling service.
I will not rent, sell, or share personal information about you with other people or non-affiliated companies except under the circumstances explained further on.
INITIAL INTAKE PROCEDURE
During the initial intake for online counselling, you will be sent a client questionnaire. The information you provide in this form is sent over a secure, encrypted email connection and available only to the intended recipient, in this case gestalt-counselling.co.uk.
As a registered accredited member of the British Association for Counselling and Psychotherapy (BACP) I will endeavor to provide the highest level of confidentiality possible according to the law and the Code of Ethics. To support good practice as required by BACP I have regular clinical supervision and may discuss our work with my supervisor. All clients are presented under a pseudonym to protect their identity and fully maintain confidentiality.
As required by my professional organisation I have appointed a clinical professional as trustee who, in the event of my sudden, long term or permanent absence from work, will be given access to your records to contact you so that your needs can be provided for.
There are circumstances recognised or required by law where a therapist may seek, or be obliged, to break confidentiality:
· if I become concerned about your personal safety, the possibility of you injuring someone else or about you receiving proper care, I will do whatever I can within the limits of the law to prevent you from injuring yourself or others and ensure that you receive the care you need.
· if you intend to commit and have committed a serious crime;
· If you intend to commit and have committed an act of terrorism against the State;
· and in relation to any matters concerning child protection.
For this purpose, I may also contact law enforcement, hospital or an emergency contact whose name you have provided. Unless there are particularly urgent factors to consider, I will usually try to discuss this with you first.
To ensure the best level of care for you in the case of an emergency during our work, I may request your permission to contact your GP and/or support you in doing so yourself, and/or recommend alternative forms of support. I may also utilise search engines as a means of collecting client information in case of emergencies as part of providing clinical care and/or assessment. This will be documented in your client notes.
SOCIAL MEDIA POLICY
Please note I do not engage with any client or former client on social media (e.g., Facebook, Twitter, blog comments, etc.) and will therefore ignore any requests for “friendship,” business contacts, direct or @replies, blog responses or requests for a blog response within social media sites, to preserve the integrity of our therapeutic relationship and protect your confidentiality.
However, the internet makes this sometimes difficult, so please raise any issues that may occur in relation to social media interaction in our sessions.
CONFIDENTIALITY OF EMAIL/SMS/MOBILE/TELEPHONE/IM/ZOOM
Therapeutic email exchanges are delivered via a secure and encrypted third party host. You agree to work with me online using encrypted email/chat service determined to be suitable by me. If you choose to email me from your personal email account, please limit the contents to housekeeping issues such as cancellation or change in contact information. I will not respond to personal therapeutic concerns via regular email.
If you call me, please be aware that unless we are both on land line phones, the conversation may not be confidential. Likewise, text messages may not be confidential. You understand that emails between sessions that contain confidential information will be sent utilizing encryption. We make every effort to keep all information confidential.
Likewise, if we are working online together, I ask that you determine who has access to your computer and electronic information from your location. This would include family members, co-workers, supervisors, and friends. Please do not compose or send emails through workplace computers, email addresses or networks. Many employers screen emails and others will be able to read your emails, especially if your PC or laptop is shared. We encourage you to only communicate through a computer that you know is safe.
Be sure to fully exit all online counselling sessions and emails.
DATA PROTECTION SECURITY
I employ administrative, physical, and technical measures designed to safeguard and protect information under my control from unauthorised access, use, and disclosure. Despite these measures, you understand that the confidentiality of any communication or material transmitted to or from us by internet or email, or any electronic storage system or third-party host/platform, cannot be guaranteed.
If you have reason to believe that your interaction with me is no longer secure, please notify me immediately of the problem. In addition, if you have privacy or data security-related questions, please feel free to contact me as per my website page.
DATA PROTECTION AND GDPR COMPLIANCE/STORAGE AND RECORD KEEPING
Personal data is information relating to an identified or identifiable natural person, such as your name, age, address, date of birth, gender and contact details. It may contain information which is known as special categories of personal data relating to and not limited to, your health. A ‘data controller’ ‘says how and why personal data are processed. In private practice, therapists who manage their own business, will therefore be ‘data controllers’. As a data controller, I am directly accountable for data processing. By completing my intake form you will provide me with basic personal data which I require for administration purposes and in case of emergency or acute crisis as specified under ‘CONFIDENTIALITY’.
Practitioners create, maintain, and store records related to their professional work to facilitate care by them or other treating professionals, and to ensure compliance with legal requirements. I am required by the BACP to keep appropriate records of our work unless there are adequate reasons for not keeping any. All messages exchanged with clients may become a part of the clinical and legal record.
The EU General Data Protection Regulation (GDPR) and Data Protection Act 2018 requires that all records on clients are kept in a secure place, protected from unauthorised disclosure, and stored separately from any personal data that could identify you. Accordingly, email addresses, credit card information and client records are stored separately on password protected flash drives that are safely stored. All electronic records of client sessions will be deleted at the end of our therapeutic work and all my manual records on clients are kept in a secure and locked place and kept for seven years. I am also registered as a Data Controller with ICO (www.ico.org.uk.), the Information Commissioner’s Office, under registration code ZA160933 and pay an annual fee to them.
I do not share your personal data or email address with third parties unless I have your explicit consent. Both the GDPR and DPA 2018 give statutory protection to the privacy and confidentiality of personal data. There are exemptions which permit the disclosure of personal data for the prevention or detection of crime and if I am required to disclose by or under any UK enactment, any rule of common law or an order of a court or tribunal in any jurisdiction. Under data protection law, you have the right
– to access a copy and explanation of your personal data
– to request correction or erasure, in certain circumstances
– to request limiting or ceasing data processing, where applicable
– to compensation for substantial damage or distress caused by data processing, where applicable.
All information disclosed within sessions and the written records pertaining to those sessions are confidential and may not be revealed to anyone without your written permission, except where disclosure is required by law.
Likewise, you are expected to keep our communications confidential, and you understand that all records of communication between client and counsellor remain the property of the counsellor. Circulating extracts or whole copies of direct information or verbatim transcripts of exchanges with the counsellor, to any third parties and/or on social media is a breach of law.
LINKS TO OTHER SITES
My website pages offer you the opportunity to access third-party content or services by linking to a third party’s website. If you choose to click a third-party link, you will be directed to that third party’s website. This is not an endorsement, authorisation, or representation of my affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices.
I do not exercise control over third party websites. These may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other services follow different rules regarding the use or disclosure of the personal information you submit to them. I am not responsible for the privacy practices or the content of other websites. You should check the privacy policies of those sites before providing your personal information to them.
The gestalt-counselling.co.uk service is not suited for children. I do not knowingly collect personally identifiable information from anyone under the age of 18. If I suspect you are under 18, I will refer you to an appropriate service.
PAYMENT OF SESSIONS
All payments for online counselling are made securely via PayPal using your debit or credit card. It is one of the most secure forms of payment over the internet. You do not need to have a PayPal account to make a payment via PayPal. All major credit and debit cards are accepted.
Face to face counselling fees will be paid at the beginning of sessions.