Privacy policy

Your privacy is very important

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 (as outlined in the Counselling Contract). 

I adhere to current data protection legislation, including the General Data Protection Regulation EU/2016/679 (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.

Why I can process your information and what purpose I am processing it for

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 now ended, I will use legitimate interest as my lawful basis for holding and using your personal information. 
• 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 me processing any special categories of personal information is that it is for the provision of health treatment (in this case counselling) and necessary for a contract with a health professional (in this case, a contract between me and you).

When you visit my website

I use a third-party service (Go Daddy) to collect standard internet log information, Google analytics, and details of visitor behaviour patterns. This information is processed in a way that does not identify anyone. I do not make, and do not allow Go Daddy 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.

When you register to access pages and the booking and payment systems on the website, your name, email address and your telephone number are saved by Go Daddy in order to grant you access. This information is retained for the duration of your account. Your password is private to you and is not read or stored by the website or Go Daddy. It is your responsibility to protect your password and not share it with anyone else. 

When you send in an enquiry or make initial contact

When you complete the Contact Me form or contact me directly with an enquiry about my counselling services, I will collect information to help me satisfy your enquiry. This will include your name, contact information and why you are seeking counselling. Only contact details are stored on the website (name, email and phone number). Any further information provided by you is stored securely as a hard copy, and information is not shared with any third party. If counselling does not proceed, your prospective-client enquiry details will be retained for a period of 6 months. If you have not contacted me in this time your details will be destroyed. If you would like me to destroy your information sooner, please let me know in writing and I will ensure all your personal data is deleted within 14 days. 

While you are accessing counselling

Rest assured that everything you discuss with me is confidential. 

Confidentiality will only be broken if:

• you disclose involvement in, or knowledge of, an act of terrorism, money laundering or drugs trafficking
• you report instances of serious harm to self or to others
• I have to report harm or abuse to a minor or vulnerable adult
• I am legally compelled to provide information at the request of a  court of law

I will always try to speak to you about this first, unless there are safeguarding issues that prevent this (for example, if that would increase the risk of harm).

When you make a payment using the payment link

I use PayPal links to allow access to pay by this method. PayPal is a well-known and trusted site used by many.  Alternatively, the Azure Dragonfly Counselling bank details are provided on the website and in the Counselling Information and Contract form for anyone wishing to pay by direct bank transfer instead. Both PayPal and the Azure Dragonfly bank accounts will show your name and any reference input by you on bank statements. I have no control over the electronic storage of this information, but any printed material is kept securely in a locked cabinet, and any electronic data is password protected and, where possible, uses 2-step authentication.

Record keeping

I will keep a record of your personal details to help the counselling service run smoothly. These are locked in a secure cabinet.

• I will keep minimal, basic and factual notes of each session. These are stored securely in hard copy.
• For security reasons I do not retain text messages for more than 7 days. Likewise, any email correspondence will be deleted after 7 days unless it is important to our work together. 
• I will keep a paper copy of your counselling contract, and a record of session attendance. These details are stored in a locked drawer and kept while we are working together and for a required period of 7 years following the final counselling session. 
• I keep a record of fees and payments for admin purposes.

After counselling has ended

Once counselling has ended, I am required to retain records of our work together for 7 years from the end of our contact with each other, and they are then securely destroyed. If you want me to delete your information sooner than this, please put your request in writing and this will be duly processed in accordance with advice from BACP,  my insurers and the ICO.

Your rights

You have a right to ask me: 

• to delete your personal information 
• to limit how I use your personal information 
• to stop processing your personal information
• to ask for a copy of any information that I hold about you 
• to object to the use of your personal data in some circumstances 

If I do hold information about you, following a written request, 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 
• tell you how I made this decision 
• tell you who it could be disclosed to 
• let you have a copy of the information that is personal to you 

You can also ask me to correct any mistakes there may be in the personal information I hold about you, such as spelling mistakes or factual inaccuracies. 

To make a request for any personal information I may hold about you please put the request in writing, addressing it to jacqui.miller@azure-dragonfly-counselling.co.uk 

Complaints

I am happy to talk through any questions you might have about my privacy and data protection policy, and you can contact me via the contact page on my website or via my email address. 

If you have a complaint about how I handle your personal data, please do not hesitate to get in touch with me by emailing. I would welcome any suggestions for improving my data protection procedures. 

If you want to make a formal complaint about the way I 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. 

Information

‘Data controller’ is the term used to describe the person/organisation that collects, stores, and has responsibility for people’s personal data. In this instance, I am the data controller.

I am registered with the Information Commissioner’s Office [registration: ZB560311]. 

My trading name is: Azure Dragonfly Counselling. 

My phone number is: 07938 66 99 78. 

My email address is: jacqui.miller@azure-dragonfly-counselling.co.uk

My website address is: https://azure-dragonfly-counselling.co.uk