Privacy Statement

INTRODUCTION:

Your privacy is important to me and you can be confident that your personal information will be kept securely and will only be used for the purpose it was given to me. I 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 I will do with your personal information from initial point of contact through to after your therapy has ended.

 

‘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 me.

 

Please contact me on the details below if you have any questions about my data protection policy.

 

I am registered with the Information Commissioner’s Office: Registration number: ZA444785

 

My postal address is 92-94 Tooley Street, London, SE1 2TH. My email address is: nadiaduggal@hushmail.com

 

MY LAWFUL BASIS FOR HOLDING AND USING YOUR PERSONAL INFORMATION:

The GDPR states that I must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which I am processing your data. I have explained these below:

If you have had therapy with me and it has now ended, I will use legitimate interest as my lawful basis for holding and using your personal information.

If you are currently having therapy or if you are in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of our contract.

The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for me processing any special categories of personal information is that it is for provision of health treatment (in this case counselling and psychotherapy) and necessary for a contract with a health professional (in this case, a contract between me and you).

 

HOW I USE YOUR INFORMATION:

Initial contact:

When you contact me with an enquiry about my counselling and psychotherapy service, I will collect personal information from you to help me satisfy your enquiry. This may include your name, address, date of birth, telephone numbers, email address, emergency contact information, GP details and information relevant to your reason for seeking counselling or psychotherapy.

 

Alternatively, your GP or other health professional may send me your details when making a referral or a parent or trusted individual may give me your details when making an enquiry on your behalf.

 

If you decide not to proceed with counselling or psychotherapy, I will ensure all your personal data is deleted within one month. If you would like me to delete this information sooner, just let me know.

 

While you are accessing counselling or psychotherapy:

 

On entering into a counselling or psychotherapy contract with me I will ask you to provide me with additional information in the form of an assessment questionnaire that is relevant to our work together, this may include for example: your goals for therapy, details of previous therapy or treatment, your health and physical wellbeing, past or current use of medication, employment history, alcohol or drug use, family history and structure, education and significant partners. Any information you provide for these purposes will have your identifying details removed and will be kept securely and separately from the personal contact data I hold about you.

 

I will keep a record of your personal details to help my counselling and psychotherapy service run smoothly. These details are kept securely and are not shared with any third party. I will also keep written notes of each of our sessions and hold these separately from your personal details.

 

For security reasons I do not retain text messages received from you for more than two weeks. If there is relevant information contained in a text message, I will transfer it to the other records I hold for you. Likewise, any email correspondence will be deleted after one month. If necessary, I will transfer this to your records.

 

Limits to confidentiality:

 

Everything you discuss with me is kept confidential. Confidentiality will only be broken if it is required by law or if it is considered that there is a real possibility of harm to yourself or others. Some possible examples of the circumstances where confidentiality may be broken are:

  • If I am required to give evidence by a court order

  • Safeguarding concerns relating to the welfare of a child or adult

  • If you are judged to be actively suicidal or a risk to yourself

  • In cases involving terrorism, fraud or money laundering

  • Wherever possible I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.

 

After our work together has ended

 

Once our contract has ended your records will be kept for seven years from the end of our contact with each other to meet legal and insurance requirements. Following this period, they are securely destroyed. If you would like me to delete your information sooner than this, please tell me.

 

THIRD-PARTY RECIPIENTS OF PERSONAL DATA:

I sometimes share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks such as hosting my email service, providing me with a mobile phone service or providing online payment facilities. In such cases I have carefully selected which partners I work with. I take great care to ensure that I have a contract with the third party that states what they are allowed to do with the data I share with them. I ensure that they do not use your information in any way other than the task for which they have been contracted.

 

In line with best practice guidelines for counselling and psychotherapy I have regular clinical supervision. I do not disclose any personally identifying information about my clients within supervision.

 

DATA SECURITY:

I take the security of the data I hold about you seriously and as such I make every effort to make sure it is kept secure. The devices I use to access, process and store your data on are used solely by me, are password protected and use encrypted storage. My email service also uses encryption.

Where I hold paper records containing your personal data these are kept securely in a locked, filing cabinet which his used solely by me. As outlined above I regularly delete text messages and emails received from clients in order to minimise the risk of a data breach.

 

YOUR RIGHTS:

I endeavour to be as transparent as I can be in terms of giving clients access to their personal information. You have a right to ask me to delete your personal information, to limit how I use your personal information, or to stop processing your personal information. You also have a right to ask for a copy of any information that I 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 I do hold information about you I will:

 

  • give you a description of it and where it came from;

  • tell you why I am holding its, tell you how long I will store your data and how I 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 me at any time to correct any mistakes there may be in the personal information I hold about you.

 

To make a request for any personal information I may hold about you, please put the request in writing addressing it to: nadiaduggal@hushmail.com

 

If you have any complaint about how I handle your personal data please get in touch with me by writing to the contact details given above. I would welcome any suggestions for improving my data protection procedures.

 

If you want to make a formal complaint about the way I 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.

 

VISITORS TO MY WEBSITE:

When someone visits my website, I use a third-party service, ‘Google Analytics’, to collect standard internet log information and details of visitor behaviour patterns. I 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. I do not make, and do not allow ‘Google Analytics’ or my web hosting service to make any attempt to find out the identities of those visiting my website.

I use legitimate interests as my lawful basis for holding and using your personal information (e.g. your IP address) in this way when you visit my website.

We receive, collect and store any information you enter on our website or provide us in any other way. In addition, we collect the Internet protocol (IP) address used to connect your computer to the Internet; login; e-mail address; password; computer and connection information and purchase history. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. We also collect personally identifiable information (including name, email, password, communications); payment details (including credit card information), comments, feedback, product reviews, recommendations, and personal profile.

When you conduct a transaction on our website, as part of the process, we collect personal information you give us such as your name and email address. Your personal information will be used for the specific reasons stated above only.

We collect such Non-personal and Personal Information for the following purposes:

  • To provide and operate the Services;

  • To provide our Users with ongoing customer assistance and technical support;

  • To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages;

  • To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;

  • To comply with any applicable laws and regulations.

Our company is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.

All direct payment gateways offered by Wix.com and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.

We may contact you to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, to send updates about our company, or as otherwise necessary to contact you to enforce our User Agreement, applicable national laws, and any agreement we may have with you. For these purposes we may contact you via email, telephone, text messages, and postal mail.

It's important to note that third-party services, such as Google Analytics or other applications offered through the Wix App Market, placing cookies or utilizing other tracking technologies through Wix´s services, may have their own policies regarding how they collect and store information. As these are external services, such practices are not covered by the Wix Privacy Policy.

Wix uses cookies for important reasons, such as:

  • To provide a great experience for visitors and customers.

  • To identify registered members (users who registered to your site).

  • To monitor and analyse the performance, operation and effectiveness of Wix's platform.

  • To ensure our platform is secure and safe to use.

Types of Cookies

In general, the cookies which are initially placed on your Wix website may be categorized as essential cookies. However, considering that our platform gives you the ability to add multiple components, codes, third-party applications...and so on, your website may include other types of cookies which might require specific settings.

Take a look at the table below to see which cookies we place on Wix sites:

Cookie Name                     Purpose                                                                                   Duration                                             Cookie Type

XSRF-TOKEN.           Used for security reasons                                                                 Session                                                   Essential

hs                             Used for security reasons                                                                  Session                                                   Essential

svSession          Used in connection with user login.                                                       2 years.                                                  Essential 

SSR-caching.    Used to indicate the system from which the site was rendered         1 minute                                                Essential

_wixCIDX.         Used for system monitoring/debugging                                                 3 months                                              Essential

_wix_browser_sess    Used for system monitoring/debugging                                      session                                                 Essential

consent-policy     Used for cookie banner parameters                                                   12 months                                             Essential

smSession        Used to identify logged in site members                                                 Session                                                Essential

TS*                   Used for security and anti-fraud reasons                                                 Session                                               Essential

bSession.     Used for system effectiveness measurement.                                          30 minutes                                            Essential

fedops.logger.sessionId  Used for stability/effectiveness measurement                    12 months                                              Essential

wixLanguage Used on multilingual websites to save user language preference.      12 months                                           Functional

 

If you don’t want us to process your data anymore, please contact us at nadiaduggal@hushmail.com.

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

If you would like to: access, correct, amend or delete any personal information we have about you, you are invited to contact us at nadiaduggal@hushmail.com .

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© 2020 Nadia Duggal Infinity Counselling London.