PRIVACY POLICY
Protecting your privacy is important to me
Contact Information
Jackie Hill
Business address: The Willows Centre, 2 The Drive, Harold Wood, RM3 0DU
0044 (0) 7426088501
jackie@jackiehillcounselling.com
www.jackiehillcounselling.com
Jackie Hill Counselling is the business name of sole trader, Jackie Hill
I, Jackie Hill am the Data Controller and Processor of Jackie Hill Counselling/Romford Counselling Psychotherapy Hypnotherapy Service.
Website
Jackie Hill Counselling Service is strongly committed to protecting your privacy and complying with your choices. The use of the Internet pages of the WEBSITE OF JACKIE HILL COUNSELLING is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary – for example buying products from my shop, or subscribing to my blog.
If the processing of personal data is necessary and there is no statutory basis for such processing, I generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the website jackiehillcounselling. By means of this data protection declaration, my enterprise would like to inform the general public of the nature, scope, and purpose of the personal data I collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
Notice
I will clearly inform you when information that personally identifies you (“personal information”) is asked for and you will have the choice to provide it or not. Generally, this information is requested when you when you receive products, and/or subscribe to my newsletters and product updates, or other online services.
Consultation and Treatment Sessions
The basis on which I keep client data is that of “Legitimate Interests”. This means that the data is necessary for me to fulfil the contract that we have together (i.e. to provide therapy) and that it is data that you would reasonably expect me to hold and use.
For those who enquire about therapy, the data I hold includes any information you have sent me by email/text/message.
For those who book and attend at least one session, the data I hold includes:
- Basic information such as name, email address, phone number
- Information that you give me as part of the work we do together
- Records of what interventions that I use (or potentially do not use) in our sessions
- Emails, texts and/or messages that are sent between us
- Information sent from any third party, e.g. GP, insurance company, EAP
Some of the information that you give me may fall under the definition of special category of data as defined by the General Data Protection Regulation. The condition for processing this special data is (précised from the Act) “processing is necessary for medical diagnosis, the provision of health care or treatment pursuant to contract with a health professional”.
Data is not shared with anyone, except possibly your GP, and for any reasons covered by the Requirements for Disclosure which are detailed and discussed when we first meet. My accountant will see bank, credit card and PayPal records which will contain any information that you submit when making payment. If you would like me to redact your identifiable data before sending to the accountants then please let me know.
The data is primarily used to enable me to provide therapy for you. It may also be used scientific research purposes and statistical purposes.
Details of where data is
- Any emails sent between us are held either on my computer’s hard drive or if archived, in Dropbox which is secure cloud based storage which is itself GDPR compliant.
- Any texts/WhatsApp messages/Messenger messages sent between us (See Social Media and Electronic Information section) are held on my iPhone which is code protected.
- Your notes are typed and held in a file with password protected on the hard drive of my computer. Any handwritten notes I take during our meetings are shredded as soon as they are typed and stored on my computer.
- If you use PayPal or online banking then clearly these systems will hold your data. I will download from these systems for accounting purposes and the resulting spreadsheets are held in a password protected file on the hard drive of my computer. When sent to my accountants, they will be password protected through dropbox or printed and given by hand,
- Any audio recordings that are made specifically for you will be password protected and held on my hard drive on the computer,
Your data is kept for 7 years. The length of time is based on the stipulation of my insurer. After this time any paper records are shredded and computer records permanently deleted.
Jackie Hill Counselling takes the security of data seriously and as such:
- All data is held securely (see details of where data is held above)
- Any data transmitted is sent encrypted where possible
- For accounting purposes Excel spreadsheets are used.
However,
- I am not in control of data (including emails and texts) which you send me
- Apps such as Facebook routinely access any information held and this is beyond my control.
If there is any breach of data security Jackie Hill Counselling will give full details to the Information Commissioners Office and any person affected within 72 hours of the breach and do all possible to minimise any potential impact.
You have rights with regards to the data held:
- The right of access. I will provide you with all data I hold on you as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).
- The right to rectification. If any data I hold is incorrect, just let me know and I will correct it as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).
- The right to erasure. If you wish me to erase your data just let me know and I will delete any computer records and shred any paper records as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness). NB: data may be retained for scientific research, historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing but this would never include case notes or data such as address/email/phone
- The right to restrict processing. This would usually be a stop-gap measure before correction of any errors or before erasure
- The right to data portability. This might apply if you want your notes sent to another therapist for example, but it is likely that the easiest solution would come under the right to access, i.e., I would send the data to you.
- The right to object to:
- Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling). Jackie Hill Counselling does not engage in these things
- Direct marketing. From time to time you may be contacted by email from me with news and details of products, blog updates, webinars etc which may be of interest to you. Your consent for direct marketing will always be required and at any time you can opt out.
- Processing for purposes of scientific/historical research and statistics. For this, you must provide grounds for your objection.
- Automated decision making and profiling. Jackie Hill Counselling does not engage in automated decision making or profiling
Consent
When you provide your personal information, you consent that it can be used for the above purposes and that Jackie Hill Counselling is an authorized holder of such information. If you choose not to register or provide personal information, you can still use our website but you will not be able to receive additional services or access certain areas that require registration. In each communication from me you will have the opportunity to unsubscribe from further communications; alternatively you may contact me to express your choices on jackie@jackiehillcounselling.com
Security of Information
I am strongly committed to protecting your information and ensuring that your choices are honored. I have taken strong security measures to protect your data from loss, misuse, unauthorized access, disclosure, alteration, or destruction.
Your information is never shared outside the company without your permission. I may on occasion require the help of other companies to provide limited services on our behalf, such as packaging, shipping and delivery, customer support and processing event registrations. I will only provide such companies with the information required for them to perform these services; these service providers are bound by strict privacy policies and are prohibited from using your information for any other purpose.
In very rare instances Jackie Hill Counselling service may disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Jackie Hill Counselling Service or the site; (b) protect and defend the rights or property of Jackie Hill Counselling Service and its family of websites and properties; and (c) act in urgent circumstances to protect the personal safety of users of Jackie Hill Counselling Service, its websites, or the public.
How to opt out
I provide users with the opportunity to opt-out from receiving updates on our products, newsletters and other communications from us. You can opt-out by clicking on the link provided in our electronic mailings or by contacting us direct.