Privacy Policy
Introduction
When working with clients and providing counselling services, Holistically Human collects some personal information to ensure safe and effective counselling. adheres to the General Data Protection Regulations (GDPR) and the British Association of Counselling and Psychotherapy (BACP) Ethical Framework for the Counselling Professions when handling this information.
While clients are not legally required to provide this information, Holistically Human cannot offer services without it. Clients are encouraged to discuss any privacy concerns with administration.
Information we collect
Holistically Human collects and processes some personal data to provide a counselling service, this includes:
- Personal identifiers, contacts and characteristics – for example, name, contact details, age and ethnicity;
- Some health details which may be relevant to the counselling process
- Emergency contact details
Information is collected by being provided by a service user, ensuring consent is provided. Occasionally, we may get enquiries and collect information from third parties, more information is available in our Confidentiality Policy.
To ensure we comply with GDPR we must lawfully process personal data for specific purposes under multiple legal basis:
- We have your explicit consent. You have the right to remove your consent at any time;
- We have an ethical obligation;
- We have a legal obligation;
- We have legitimate interest
How we use the information
Holistically Human uses information a service user has provided to ensure we can offer and provide the most appropriate service.
Confidentiality is explained to service users at multiple occasions, including assessment and the first session with their counsellor. There are exceptional circumstances which may mean confidentiality needs to be breached. Exceptions include situations where the information contravenes the law, endangers others, or involves an emergency that threatens life or physical safety. Confidentiality does not extend to potential safeguarding issues. Wherever possible, this is to be done with knowledge and consent from the client.
Service users have the right to file a complaint if their information is disclosed without their consent. The complaint will follow the procedure set out in Holistically Human’s Client Complaints Policy.
How the information is stored
We hold information provided by service users in our secure system. This is system is specifically used for the purpose of running the counselling service.
How long we hold information
The time limit for storage of general non-active information will be 7 years, where this is a legal requirement to do so. Information where there is no such legal requirement will be stored for an appropriate period, which may, on occasion, be specified. There may be instances in which information of a personal nature is held longer than 7 years at Management’s discretion.
Data Protection Rights
Under data protection law, clients have specific rights, including:
- A right of access, to ask for copies held of personal information;
- A right of rectification, to ask that any inaccurate information be corrected. This also includes asking for any incomplete information to be added to;
- A right to erasure, to ask for information to be erased in certain circumstances;
- A right to restriction of processing, to ask that processing of information is restricted in certain circumstances;
- A right to object to processing, to object to the processing of information in certain circumstances;
- A right to data portability, to ask that information be transferred to another organisation or to the client, in certain circumstances
Requests can be made directly to Holistically Human for the above rights. Holistically Human will arrange for the data subject to see or hear, or delete all personal data held about them within 21 days of receipt of a written request to enquires@theholistichumans.com.
More information about data processing can be found from the Information Commissioner’s Office (ICO) www.ico.org.uk . Service users can also complain directly to the ICO if they are unhappy with how Holistically Human have used their data.
Review
This policy is reviewed every 3 years.