Client Privacy Policy
In 2018, data protection law changed with the introduction of the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. These regulations ensure that your personal and sensitive information is held securely, lawfully and transparently. This policy explains how and why I collect, store and use your personal information.
Who is the Data Controller and what is their ICO registration number?
The Data Controller is Ellen Vintner.
ICO Registration Number: C1333709
If you have any questions about this policy, please contact: counselling@ellenvintner.org
Why do I hold your data?
I only collect data that is necessary for our therapeutic relationship and to ensure that I can contact you and your designated emergency contact person if required. I will write brief, relevant notes after each session which will be stored safely and pseudonymised as outlined below. You have the right to access the personal information I hold about you, including your notes.
How do I collect your data?
Information l have on file for you will have been provided to me by you. Any information provided to me by a third party will usually only be accepted with your permission. Anonymous information may be collected when you visit my website, such as visitor numbers, approximate location and how the website is used.
How will your data be stored?
Personal data that is stored digitally, such as name and address, will be password or passcode protected. Notes that I make after each session will be pseudonymised and stored securely and separately from identifying information.
How long will I hold your information for?
Records will be stored securely for 7 years after the last interaction with an adult client and up to the age of 25 for a child under 18 when last seen. This is in line with my professional insurance requirements.
What if you would like your data to be destroyed before this date?
You can request deletion of your records, and I will comply where this does not conflict with legal, safeguarding, professional or insurance obligations. If you wish to do this then please contact me on counselling@ellenvintner.org. Your request for deletion would be saved.
Can you request a copy of the information held by me?
You may request details of personal information held about you under UK GDPR and the Data Protection Act 2018, and I will comply within 30 days. If you believe that any information I am holding on you is incorrect or incomplete, then please email me as soon as possible at the above address. I will promptly correct any information found to be incorrect.
When would I share your data?
If you or someone else is at serious risk of harm, I may need to break confidentiality. This may require me to share information with an appropriate professional, such as your GP. Wherever possible, I will try to discuss this with you first and explain my concerns and any actions that may be necessary to keep you or others safe. This is in line with the working agreement provided alongside this policy.
When working with a person under the age of 18, the same principles apply. I will usually involve parent(s) or guardian(s) where appropriate, unless this increases risk or the young person is competent to consent. In such cases, I may need to share relevant information with an appropriate professional or agency in order to keep them safe.
I would also need to break confidentiality if you disclosed knowledge of, or involvement in, harm to a child or vulnerable adult.
If you require emergency medical assistance, or if your behaviour requires me to contact the police, I may need to share limited personal information to keep you, myself or others safe. I will try to speak with you first unless prevented from doing so by the urgency of the situation or by legal constraints.
There are limited occasions where I may be legally required to disclose information without your consent, including Court Orders and disclosure of involvement in acts of terrorism, money laundering, people trafficking or drug trafficking. This does not include the recreational use of drugs.
In the event of my death or significant incapacity, I maintain a Professional Will. A named counselling professional is authorised to access relevant client contact details and records only for the purpose of informing you of my absence and to support the safe closure or transfer of work.
Are our discussions within the counselling sessions confidential?
Our discussions are confidential within the parameters set out above. I attend regular clinical supervision to ensure that I am always working in your best interest. During supervision your anonymity will always be protected.
What if you see me outside of a counselling session?
I will not acknowledge you unless you choose to acknowledge me first.
Will I discuss information about you with another health or social care professional?
Usually only with your consent. However, there are limited circumstances where I may need to share relevant information without your consent in order to keep you or others safe, or to comply with legal or safeguarding obligations, as outlined above.