Privacy Policy
Background
In order to provide you with the best service possible we need to hold your personal contact details and, in some cases, the records of your therapy sessions. This privacy notice tells you what we will do with your personal information from initial point of contact through to after therapy has ended. Your privacy is very important to us and 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. We also adhere to the ethical guidelines regarding protecting client privacy and confidentiality set by the British Association for Counselling and Psychotherapy (BACP).
When you contact Online Therapy UK through our enquiry form, you give us consent to store your personal information in order to provide our services to you. Routinely, we will only share this information with the therapist/therapists who we believe would be a good match for you, however there are some instances in which we have to share it to third parties. Please read this Privacy Policy carefully so that you understand how we handle your data.
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. If you have had therapy with any of the therapists within the Standard or the Low-Cost Therapy Service, 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 within the Low-Cost Therapy Service 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 the service we offer or 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 that it is for provision of health treatment (in this case therapy sessions) and necessary for a contract with a health professional (in this case, a contract between you and your therapist).
If you are currently having therapy with one of our Fully Qualified Counsellors/Psychotherapists or you have finished therapy with them, they will keep your sensitive information and your session notes in accordance with GDPR rules and BACP’s/NCPS’s/BPS’s guidelines. Online Therapy UK will retain your name, your email address, your phone number, an anonymised summary of your struggles and the dates when you entered and finished therapy on their system for up to five years of the date when you finished therapy.
Information we record
The information we request from you may include personal information, such as your full name, your phone number, your email address, you GP details, and your date of birth. We may also ask for sensitive personal information, such as ethnicity, gender sexuality, marital status, sexuality, offences, the status of your physical and mental health or religion and beliefs
If you are currently having therapy withing our Low-Cost Therapy Service, Online Therapy UK will also hold information such as anonymised therapy session notes, anonymised risk assessments and safety plans. If you are currently having therapy with one of the Fully Qualified Counsellors/Psychotherapists and you want to know how they process the information about you, you can ask them directly.
How we use your information
We will never use your personal data for any purposes other than a) matching you with an Associate Counsellor/Psychotherapist or a Trainee Therapist or b) the administration of the therapy service provided to you i.e. to arrange, cancel and rearrange appointments. We will only retain your personal information for as long as it is necessary. This is in line with guidance from the Information Commissioner’s Office.
The personal information we collect about those who use our services is used to provide the services requested and to operate our business efficiently. We use it for billing, identification, authentication, service improvement, research, and for contacting you when necessary.
If you engage in therapeutic services within our Low-Cost Service we will hold your contact details, and personal information which we: a) collect through the Enquiry Form on this website, and b) take as part of the clinical assessment required to provide that service to you. This information is held securely, and we use computer equipment with Virus Protection to process and store this information.
If you engage in therapeutic services in our Standard Therapy Service, you may be seen by a Fully Qualified Counsellor/Psychotherapist. Online Therapy UK will only store the information you enter via the Live Booking System. Any clinical documentation will be stored by the Fully Qualified Counsellor/Psychotherapist. All Fully Qualified Counsellors/Psychotherapists are contractually bound to ensure their handling of personal data is in line with requirements of General Data Protection Regulations (GDPR).
If you access our training or workshops, we will hold your information for the purposes of contacting you and for billing.
After therapy has ended: There are reasons why we might be required to keep records after your therapy has ended. For example, in the case of financial transactions personal information must be retained for as long as legally required in respect of tax or accounting purposes. In case of therapy within the Low-Cost Therapy Service, retaining your anonymised therapy notes ensures that we can continue to offer you an efficient service if you make contact after therapy has ended. Your therapy notes do not include any personal details that could be used to identify you and continue to be stored securely on our password-protected files on a password-protected computer equipment for two years after your therapy has ended. Two years after therapy has ended your therapy notes will be confidentially destroyed.
Your personal details form is confidentially destroyed five years after ending of your therapy sessions. Please note that we need to keep a record of your name, date of birth, email address and your client reference number for two years after your therapy has ended. Your client reference number corresponds with a client reference number on your therapy notes and therefore enables us to identify your therapy notes if necessary.
Third party recipients of personal data
We share a limited amount of personal data with third parties in order to provide our services to you and to fulfil legal obligations in respect of tax and accounting purposes. For example, our accountant is permitted access to our invoices. We will never pass on your contact details to any third-party organisations for the purposes of sales, marketing or research.
Data security
We take the security of the data that we hold about you very seriously. Our email account is password protected and mobile phones and laptops used to respond to your emails are password protected and have anti-virus software. Any email correspondence will be deleted within two years if it is not necessary to keep it.
Information Sharing
We may disclose personal information when we believe it violates our Terms of Service, when it is required to assist with a lawful investigation or comply with the law, if we believe disclosure is necessary to protect our rights, or if some or all of the assets and operations of our business are or may be transferred to another party.
If we believe that you or others might be at risk of harm, we reserve the right to share your personal information without your consent with either Police Service, Ambulance Service, Fire Service, Social Services or any other service which might be equipped to act appropriately. The situations where this may require are outlined in our Confidentiality Policy and Procedure.
From time to time third party service providers who assist us with our activities, such as website hosts, IT back-up service providers, and other IT or payment service providers, may also have access to personal information held by us and may use this information on our behalf.
We will not sell, rent or share your personal information with third parties in other ways without your consent unless we are entitled by law to do so.
Website visitors
By accessing the website, you are consenting to the information collection and use practices described in this privacy notice. Should you choose to contact us using the enquiry form on the website none of the data that you supply will be stored by the website or passed to any third-party data processors. Instead, the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted before being sent across the internet. The email content is then decrypted by local computers and devices.
The website uses cookies and Google Analytics. Almost all websites use cookies which are small files that get put on your computer by websites as you surf them. These cookies can store lots of information which can have privacy implications. Google Analytics is a service provided by Google that gathers anonymous data on how people are using websites and then provides visitor statistics, details of page views, etc. This service is used by many website owners as the data helps website owners to improve their websites. If you wish to change your cookie settings then you may do so through most browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them visit www.aboutcookies.org or www.allaboutcookies.org.
In many cases the cookies are used to generate identical information to Google Analytics and indeed use Google Analytics, so opting-out of Google Analytics will also opt you out of these cookies too. You can opt out of Google analytics and other Google services here – http://tools.google.com/dlpage/gaoptout and https://www.google.com/dashboard/.
When you email us
Online Therapy UK uses Google Mail and RedWebMail to supply our email service, and Red Website Design Ltd to host, manage and update our website and its contents. Both companies are required to be complaint in protecting your data.
We also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.
Your rights
Under GDPR, 2018 guidelines you have the following rights: The right to request access to the personal information that we store and process about you. You can ask for corrections to be made to the information held or for your personal information to be
deleted. You can also ask us to restrict the processing of your personal information or to object to the processing of it altogether in some circumstances. You can read more about your rights at ico.org.uk/your-data-matters. If you would like to make a request relating to any of the rights above, please send a request in writing by emailing to info@onlinetherapyuk.co.uk. Please be aware that in certain situations counsellors may be unable to comply with the above requests. For example, if compelled to retain the records by a court of law. Please also be aware that there may be a charge for complying with a request if it is deemed to be excessive in nature.
Queries
‘Data controller’ is the term used to describe the person or organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is Oktawia Blockley and she is registered with the Information Commissioner’s Office: the registration number for Mrs Oktawia Antonina Blockley is ZA765470. If you have any questions about this privacy policy or the way in which we handle your personal information you can contact us via email at info@onlinetherapyuk.co.uk.
Access and Correction
You can request access to personal information we hold about you. We will provide this except in the limited circumstances in which we are permitted not to.
You may request that we correct personal information we hold about you that is inaccurate or out-of-date. If you request that we delete your personal information, we will take all reasonable steps to do so unless we need to keep it for legal purposes or for other exemptions to the right to erasure in GDPR Article 17(3).
Complaints
If you have a complaint about how we handle your personal data, please do not hesitate to get in touch by email at info@onlinetherapyuk.co.uk. 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.
Changes to privacy notice
This privacy notice may be updated from time to time, so please check occasionally for any updates.