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Our Privacy Policy

Your privacy is important to us. 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 us. We adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.


This privacy notice tells you what we will do with your personal information from initial point of contact through to after your therapy has ended, including:
• Why we are able to process your information and what purpose we process it for
• Whether you have to provide it to us
• How long we store it for
• Whether there are other recipients of your personal information
• Whether we intend to transfer it to another country,
• Whether we do automated decision-making or profiling, and
• Your data protection rights.

We are happy to chat through any questions you might have about our data protection policy and you can contact us via email at info@bathsttherapy.co.uk


‘Data controller’ is the term used to describe the person/organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is David Bloomfield. We are registered with the Information Commissioner’s Office (David Bloomfield registration reference: ZB615150, Val Whiffen registration reference: ZB620705, Nat Porter registration reference: ZB615166). Our postal address is Bath St Therapy, 204 Bath St, Glasgow, G2 4HW. Our email address is info@bathsttherapy.co.uk


Our lawful basis for holding and using your personal information:
The GDPR states that we must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which we are processing your data. We have explained these below:


If you have had therapy with us and it has now ended, we will use legitimate interest as our lawful basis for holding and using your personal information.
If you are currently having therapy or if you are in contact with us to consider therapy, we will process your personal data where it is necessary for the performance of our contract.
The GDPR also makes sure that we look after any sensitive personal information that you may disclose to us appropriately.
This type of information is called ‘special category personal information’. The lawful basis for us processing any special categories of personal information is consent initially. We will then retain any counselling records in case of the need to reference
them in the future (the official legal basis is to defend against potential legal claims).

How we use your information:
Initial contact:
When you contact us with an enquiry about our counselling services, we will collect information to help us satisfy your enquiry. This will include details of your personal circumstances/medical history (if deemed appropriate for self-disclosure by the client), email address and name. Alternatively, your GP or other health professional may send us your details when making a referral or a parent or trusted individual may give up your details when making an enquiry on your behalf.
If you decide not to proceed we will ensure all your personal data is deleted within twelve months. If you would like us to delete this information sooner, just let us know via email.

While you are accessing counselling:
Rest assured that almost everything you discuss with us is confidential, and will remain between yourself and the therapist as contracted in the initial stages of therapy.
However, confidentiality will only be broken if counsellors are legally obliged to for the common public and legal interest. We will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
Counsellors are legally obliged to break confidentiality in instances of: clients divulging involvement, responsibility or knowledge of serious crime, terrorism, drug trafficking, traffic accidents, money laundering, and incidents raising issues around child protection. 
Further possible issues for the breaking of confidentiality include the protection of vulnerable adults, clients at serious risk of suicide or self harm, or any other disclosures legally appropriate to the public interest. For more details, please use this link: https://www.bacp.co.uk/media/16679/bacp-managing-confidentiality-lr-gpia014-nov22.pdf
We will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely and are not shared with any third party. 
We may keep written notes of each session, these are kept in a locked cupboard within secure premises that are not open to the general public.
For security reasons we do not retain text messages for more than twelve months. If there is relevant information contained in a text message we will secure it appropriately elsewhere. Likewise, any email correspondence will be deleted after seven [7] years, if/as legally appropriate.

After counselling has ended:
Once counselling has ended your records will be kept for 7 years (seven) from the end of our contact with each other and are then securely destroyed. If you want us to delete your information sooner than this, please tell us.

Third party recipients of personal data:
We sometimes share personal data with third parties, for example, where we have contracted with a supplier to carry out specific tasks. In such cases, we have carefully selected which partners we work with. We take great care to ensure that we have a contract with the third party that states what they are allowed to do with the data we share with them. We ensure that they do not use your information in any way other than the task for which they have been contracted.


Your rights:
We try to be as open as I can be in terms of giving people access to their personal information. You have a right to ask us to delete your personal information, to limit how we use your personal information, or to stop processing your persona information. You also have a right to ask for a copy of any information that we hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at ico.org.uk/your-data-matters. 
If we do hold information about you, we will:
• give you a description of it and where it came from;
• tell you why we are holding it, tell you how long we will store your data and how we made this decision;
• tell you who it could be disclosed to;
• let you have a copy of the information in an intelligible form.
You can also ask us at any time to correct any mistakes there may be in the personal information we hold about you.
To make a request for any personal information we may hold about you, please put the request in writing, addressing it to info@bathsttherapy.co.uk
If you have any complaint about how we handle your personal data please do not hesitate to get in touch with us by writing or emailing to the contact details given above. We would welcome any suggestions for improving our data protection procedures.
If you want to make a formal complaint about the way we 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.

 

Data security:
We take the security of the data we hold about you very seriously and as such we take every effort to make sure it is kept secure.
All digital data is secured via password-dependent systems and encrypted storage devices, and is deleted securely after a legally-appropriate time period.
All physical data (a rare but sometimes necessary step) is kept safely in locked cabinets and is destroyed after a legally-appropriate time period.


Visitors to our website:
When someone visits our website, we use a third party service, Wix, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. We do not make, and do not allow Wix to make, any attempt to find out the identities of those visiting our website.
We use legitimate interests as our lawful basis for holding and using your personal information in this way when you visit our website.
We use Wix’s so that we can continually improve our service to you. You can read Wix’s privacy notice here: https://www.wix.com/about/privacy
We use Wix as the content management system for our website.
Like most websites we use cookies to help the site work more efficiently - find out about our use of cookies: https://support.wix.com/en/article/cookies-and-your-wix-site
No user-specific data is collected permanently by us or any third party. If you fill in a form on our website, that data will be temporarily stored on the web host before being sent to us.
 

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