Privacy Policy 

On 25 May 2018, the General Data Protection Regulation (GDPR) came into effect. This replaced the existing Data Protection Act. The GDPR brings with it greater accountability for those who handle personal data. 

As your therapist, it will be necessary for me to handle your personal data for the general administration of my practice, and to enable me to use the full range of communication methods with you. 

This policy explains how I use personal information within my practice. Where I decide the purpose or means for the processing of personal information, I am the “data controller”. As data controller, I will comply with all applicable data protection laws. 

Personal information 

The personal information I hold about you may include:  

Identity data: title, first name, maiden name, last name, marital status, date of birth and gender 

Contact data: postal address, billing address, e-mail address and telephone numbers 

Session record: session date and time  

Name and contact details of your general practitioner  

Name and contact details of your psychiatrist 

I may note relevant material from a session(s) to further the analytic process by helping me to clarify my thoughts.  

Some personal information may be classified as "special" data under data protection legislation. This includes personal information relating to race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life and/or sexual orientation. There are restrictions on the circumstances in which I am permitted to collect and use “special” data, and I will seek your prior consent to do so. You may withdraw such consent at any time by notifying me of your wish to do so. 

How your personal information is used 

Provision of psychotherapy: 

I will use personal information to deliver psychotherapy under an arrangement between us. 

I will use personal information to communicate with you during our arrangement.  

I will keep a record of our sessions. 

Your enquiries:

Should you contact me about my practice, any electronic or written communication, including any forms I ask you to complete, might include information about you, such as your name, your e-mail or postal addresses and your enquiry. I will use this information to process and respond to your enquiries.   

In line with the legitimate interest I have in promoting my practice, I will process your enquiries to provide you with information, for example, about the therapy I offer. 

I will process your enquiries to take the steps you ask of me with a view to entering into an arrangement to provide you with psychotherapy. 

You are under no obligation to provide me with any details, you do not wish to provide. 

Disclosure to a third party 

I will disclose personal information to a third party insofar as it is reasonably necessary for the purposes set out in this policy, provided that the third party never makes independent use of the information.   

In order to contact you in the event of my death or incapacity, it will be necessary for me to entrust your personal information to two professional psychotherapist colleagues. 

In addition, I may disclose information, to the extent that I am required to do so by law (which may include to government bodies and law enforcement agencies), in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend my legal rights (including providing information to others for the purposes of fraud prevention). 

Except as set out above, I will not provide your information to a third party. 

Your rights  

You have the following rights over the way I process personal information relating to you.  I will aim to comply without undue delay, and within one month at the latest: 

  • to ask for a copy of the data I hold in relation to you, and to have inaccuracies corrected; 

  • to ask me to restrict, stop processing, or to delete your personal information;  

  • to request a machine-readable copy of your personal information, which you can use with another service provider. Where it is technically feasible, you can ask me to send this information directly to another provider, if you prefer; and  

  • to make a complaint to a data protection regulator.  

Please send your instruction by e-mail to: emmabagnallpsychotherapy@gmail.com 

Retaining personal information 

I will only retain your personal information for as long as is necessary to fulfil the purposes I recorded it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  

To determine the appropriate retention period for personal information, I consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which I process your personal information and whether I can achieve those purposes through other means, and the applicable legal requirements. 

Security 

I will take all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.  In particular, I will take precautions to protect against the accidental or unlawful destruction, loss, or alteration, and unauthorised disclosure of or access to the personal information transmitted, stored or otherwise processed by me. 

Please be aware that, while I make the security of your personal information a high priority, no security system can prevent all security breaches.  

International data transfers  

I will store your information within the UK only. I will not transfer your personal information outside the European Economic Area (EEA).