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24th April 2024 

PRIVACY POLICY



I am committed to protecting the privacy of my clients. This privacy notice sets out how I use and protect any information that you give me when you visit my website or when you contact me by other means and the lawful basis under the Data Protection Act 1998 and the General Data Protection Regulations (GDPR to be enacted May 25th 2018). You may visit my website freely without having to contact or use my services.

CONSENT TO HOLD YOUR PERSONAL DATA
By visiting my website you are agreeing to the contents of this Privacy Notice. For the purpose of the Data Protection Act 1998 and the GDPR, the data controller is Caroline Caffyn.
If you make contact via this website you can be assured any information given is held securely and will only be used in accordance with data protection principles, our data protection and confidentiality policies and our ethical principles (contained in the British Association of Counsellors and Psychotherapist (https://www.bacp.co.uk/.../ethics.../ethical-framework-for-the-counselling-professionsI) will honour the trust you have placed in me. The basis on which I hold or share information about you is outlined below and also the limits around confidentiality. I will not hold your data for longer than is deemed necessary for the purposes of counselling and following best practice and legal guidance. If you wish to know how long we hold data or notes for please contact me.


INFORMATION I COLLECT


I may collect both “Non-Personal Information” and “Personal Information” about you. “Non-Personal Information” includes information that cannot be used to personally identify you, “Personal Information” includes information that can be used to personally identify you, such as your name, address and email address.

Whether or not you become a client I will use this personal data for the purposes of initiating counselling for you. I collect the majority of this information during first contact and assessment. I will advise you if any of this data is optional.

At first contact;
I will collect the following information in order to establish if I can provide you with counselling.
Your name
Date of Birth
Contact information including your email address
Geographic information from your postcode
Other information relevant to you engaging in counselling with me, eg the name of your medical practice.
Information about any disability or communication difficulty you may have.
At first contact you may also choose whether or not to share with me a brief description of why you have chosen to seek counselling now.
Information about your education or employment status.

At Assessment;
Should you wish to continue with ongoing counselling, I will ask you to sign my Client Details Form to give me permission to process your data and also information about your healthcare professionals and emergency contact details.

During counselling;
Anonymised counselling notes. Your identity is protected and these notes are not shared with anyone unless I am legally required to do so or the client specifically requests I share them with another third party, which I have the right to refuse to do.
Personal data that identifies you and counselling notes are held separately and securely to protect your anonymity.
You have the right to view these notes and you would be advised of any request to share your notes.
These notes are the property of Caroline Caffyn and not the client.


HOW I USE AND SHARE INFORMATION
I collect this information to understand your clinical and other needs from counselling and provide you with a better service and in particular for the following reasons.
Initial record keeping
To assist with clinical assessment
For a re-referral
Referral to an external agency if necessary and for professional supervision of how I work.

The lawful basis and purpose of holding this data is to ensure I can meet the terms for providing a contract for counselling with you. I will also use your personal data to meet any legal obligations placed upon me. For instance when you exercise your rights to see what data I hold under data protection law or in order to meet any legal compliance placed on me; or occasions where I am obliged to disclose information related to safeguarding children, young people and adults at risk.

Your written consent will be sought at assessment for the need to meet possible disclosure to other bodies and for when we process any special categories of sensitive personal data about you such as gender or sexual orientation.

HOW I PROTECT INFORMATION
I take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice and for data protection and confidentiality policies.
Unfortunately the transmission of information via the internet cannot be completely secure. I have in place security measures to protect your personal data but I cannot guarantee the security of your data transmitted to my site, particularly by email. Any transmission is at your own risk. Once I have received your information, I will use my own policies and procedures as far as is reasonably possible to prevent unauthorised access.

I implement reasonable precautions and follow industry best practices in order to protect your Personal Information and ensure that such Personal Information is not accessed, disclosed, altered or destroyed.  However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such precautions. By using my Service, you acknowledge that you understand and agree to assume these risks.

CONTROLLING YOUR PERSONAL INFORMATION
I do not share your personal information with anyone else unless in pursuit of counselling on your behalf and only then if I have your permission to do so. In exceptional circumstances I may be required by law and my ethical responsibilities to break my confidentiality with you. Wherever possible I would discuss this with you first but if you do not give consent I may still have to disclose information. This relates to situations where you may be at risk of harm, causing harm to others, the safeguarding of children, young people and adults at risk, acts of terrorism and unreported road traffic accidents where we are under legal obligations.




LINKS TO OTHER WEBSITES


As part of the Service, I may provide links to other websites or applications. However, I am not responsible for the privacy practices employed by those websites or the information or content they contain. Therefore, this Privacy Policy does not apply to your use of a third-party website accessed by selecting a link via my Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. I encourage clients to read the privacy statements of other websites before proceeding to use them.




CHANGES TO MY PRIVACY POLICY


I reserve the right to change this Privacy Policy at any time. If I decide to change this Privacy Policy, I will post these changes on this page so that you are always aware of what information I collect, how I use it, and under what circumstances I disclose it. Any such modifications become effective upon your continued access to and/or use of the Service five (5) days after we first post the changes on the website or otherwise provide you with notice of such modifications. It is your sole responsibility to check this website from time to time to view any such changes to the terms of this Privacy Policy. If you do not agree to any changes, if and when such changes may be made to this Privacy Policy, you must cease access to this website. If you have provided your email address to me, you give me permission to email you for the purpose of notification as described in this Privacy Policy.



EMAIL COMMUNICATIONS & OPTING OUT


Based upon the Personal Information that you provide me, I may communicate with you in response to your enquiries to provide the service you request. I will communicate with you by email or telephone, in accordance with your wishes

CONTACT US & WITHDRAWING CONSENT


If you have any questions regarding this Privacy Policy or the practices of this Site, or wish to withdraw your consent for the continued collection, use or disclosure of your Personal Information, please contact me by sending an email to caroline@caffyncounselling.com



Last Updated: This Privacy Policy was last updated on Thursday May 24 2018.
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