Peaceful Soul Therapies, Mrs Susan Collins, 9 Penybryn, Crossgates, Llandrindod Wells, Powys, LD1 6RA, Wales
Tel: 07505133222 e-mail: firstname.lastname@example.org
The Data Controller
I am Susan Collins, BA (Hons) Counselling, MNCS (Accred.), MAC, MCMA, UK Reiki Federation Member, Member of The Reiki Association, and as owner of the business I am the Data Controller.
Peaceful Soul, previously known as Peaceful Soul Counselling, Soul Connection Holistics and Soul Connection Holistic Therapy, is my therapy business and I collect information in the natural course of dealing directly with you, either in person or by phone/text/email.
Details of Peaceful Soul’s business, online presence and contact information
Susan Collins, as owner of Peaceful Soul, and its’ predecessors, offers Counselling, Life Coaching, Mindfulness, Massage, Reiki and Ear Candling Complementary Therapies. This work is predominantly face to face and in person business, however, in the case of Counselling and Life Coaching, may also be by phone or online.
In addition to the website, there is a Facebook presence for Peaceful Soul Therapies at https://www.facebook.com/PeacefulSoulTherapies/?ref=bookmarks
How I get the personal information and why I have it
Personal information I process is provided to me directly by you for the following legitimate interest reason:
- During the natural course of business from enquiry/intake to therapy, to create your Therapy Record, to produce and process Therapy Agreements/Intake forms/questionnaires, to record brief session notes.
I also receive personal information indirectly, from the following sources in the following scenarios:
- When you visit the website, a number of cookies files may be placed in your web browser, see separate Cookies Policy for further information
The type of personal information collected
I have a legitimate interest to collect the following data during the natural course of business, from enquiry to intake to therapy.
- Full Name
- Postal Address
- Telephone number
- Mobile phone number
- Email address
- GP’s Name and Address
- A brief medical history
- Signature on Therapy Agreements/Intake Forms
- Emails and email attachments, SMS messages we have exchanged.
- The Therapy Agreement/ intake form and questionnaires which you have completed at the beginning of our work together.
- Brief notes for each session.
If necessary, I will seek your written consent to relay voice only messages, through a third party trusted by the client where you are not available to take the call. In this case an addendum is written on the Therapy Agreement/Intake Form and your signature is added to approve.
I use the information that you have given me in order to:
Information at 1-8 above inclusive are used to create the Clients’ Therapy Record and produce.
Information at 6 and 7 above is collected for the following reasons:
- If you are taken ill during a therapy session and I need to summon outside medical assistance, either from your GP or from the Emergency Services, then this information will be passed to them for them to help you from an informed position.
- In the case of Massage, 7 above allows me to assess your suitability for Massage and to ensure that you do not have a history of excluded conditions.
- Sometimes following Reiki Therapy there is a ‘Healing Crisis’ and having the information at 7 above is useful when dealing with a ‘Healing Crisis’.
- I do not, and will not, sell your data collected in the natural course of business from enquiry/intake to therapy with third parties.
- There are a limited number of circumstances in which I may share your personal data and other information with third parties:
- Where required by a court of law. This could be because it has been ordered by a court, or because the law requires, for example under the Terrorism Act 2000 or the Drug Trafficking Offences Act 1986. In these circumstances personal information may be passed without client consent.
- If your safety or that of a vulnerable adult or child is imminently at risk. So if you tell me that they intend to harm yourself or others, or if you tell be about ongoing child protection issue, then I will try to discuss it with you, and gain your consent, before taking it further.
- If you request and/or give me consent to share your information with another health professional for the purposes of improving your care.
- As required by my professional code of conduct I may discuss some aspects of my client work (anonymised, I do not disclose your name) with my supervisor who is an experienced therapist/practitioner also bound by the rules of confidentiality with the usual exceptions.
- There is a further exception to third parties in relation to website cookies and this is clearly defined as legitimate interest in the Cookies Policy, see below.
- Where a referral is to be made to another therapist, the client will be asked to sign a permission document prior to sharing authorised information.
Under the General Data Protection Regulation (GDPR), the lawful bases I rely on for processing this information is one of Legitimate Interest.
I will collect your data during phone calls, SMS text enquiries and email enquiries, session work and from completion of Therapy Agreements/Intake Forms/questionnaires.
How I store your personal information
- Your contact details and other personal information you provided in the Therapy Agreement/intake form/questionnaire are stored securely in a combination lock safe at the address detailed above.
- Your phone number is stored on my mobile phone under your initials (no surname is used). My phone is securely locked when not in use.
- Email correspondence received from you is deleted once printed; outgoing mail to you is deleted once send is complete.
- Brief session notes are kept as hard copy in a locked filing box. They do not contain your name/other personal identifiers instead they are coded for anonymity. These are kept separately from your Therapy Agreement/intake form/questionnaire that contains your personal details.
- Appointments are booked in my diary with your first name or initials only.
I have a Legitimate Interest to hold your personal data for the purposes of:
- To be able to communicate with you via phone, email or post if necessary.
- So that I have a record of your attendance and a note of important factual information that may be of significance in our work together.
- Appointments in my diary are the record I use for my accounts. In the accounts there is only ever a note of your initials and the therapy.
- For purposes of supervision which is a professional requirement for me as a Counsellor, Coach and Complementary Therapist.
- To ensure that, if I find that there is serious risk to you, or a vulnerable person / child, I could take appropriate safeguarding action.
- It is a requirement of my insurance provider, Balens Insurance Ltd.
- My insurance provider requires me to keep any client records for 7 years after completing therapy or, if you are under 18 at the time of therapy, for 7 years after you reach 18, to service any claim of malpractice being made against me.
Record Retention Period and what happens then
- A clause in my Insurance Policy requires that all notes and personal information are stored for a period of 7 years and thereafter securely destroyed. I declare that client personal information and notes are destroyed either by shredding, which is collected by my local council as part of recycling, or by burning.
- Where a client is under 18 years of age, then information is retained for 7 years from either the date of their 18th birthday or the date last therapy session, whichever is the later.
Additional information regarding Client Confidentiality
Therapy sessions are confidential; however, there are circumstances when assurance of confidentiality is beyond my control, for example:
- Re telephone and online counselling and life coaching only, you are advised to be aware that whilst using the telephone, or any other online technological platform for counselling, there is always the potential for the contact to be overheard or listened in to. If this should occur, you are asked to accept that it is a third-party issue and beyond my control.
- I give notice that when you make payment by online bank transfer then your account name will appear on my bank statement. This is a third-party issue and is beyond my control.
- Re Telephone Counselling only, I declare that following Telephone Counselling sessions I delete the call log record.
- Re Text Messaging only, a phone number is provided for cancellations or other changes to appointments. Once the text has been actioned and the conversation completed, I delete the record from the call log.
- In the case of a request by you for supporting information for provision to a third party, I print a hard copy of the request and file with your Therapy Agreement, then delete the record from either my phone or the email.
- For Emails only, once actioned, the email is printed and placed on file with your Therapy Agreement/Intake form/questionnaire, and then deleted from my computer.
Your data protection rights
Under data protection law, you have rights including:
- Your right of access – You have the right to ask us for copies of your personal information. Please contact me at Peaceful Soul Therapies, Mrs Susan Collins, 9 Penybryn, Crossgates, Llandrindod Wells, Powys, LD1 6RA, Wales, giving 30 days’ notice, if you wish to make such a request.
- Your right to rectification – You have the Right to ask for changes to the information stored, e.g. rectification of inaccurate information and completion of incomplete information. However, in this regard you need to be aware that there is a clause within my Insurance Policy requires that I keep records for 7 years. This is a legitimate interest reason which might make an actual change to client records difficult, however an addendum recording the request, and any change to agreement, will be attached to the original record. Please contact me at Peaceful Soul Therapies, Mrs Susan Collins, 9 Penybryn, Crossgates, Llandrindod Wells, Powys, LD1 6RA, Wales, giving 30 days’ notice, if you wish to make such a request.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to me at Peaceful Soul Therapies, Mrs Susan Collins, 9 Penybryn, Crossgates, Llandrindod Wells, Powys, LD1 6RA, Wales
You can also complain to the ICO if you are unhappy with how I have used your data.
The ICO’s address is:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
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