GDPR and Privacy notice

Freedom Psychotherapies Limited GDPR and customer privacy notice

This privacy notice tells you what to expect us to do with your personal information.

Contact details:

Email: freedompsychotherapies@gmail.com

Name: Beatrice Mae Ecob-Larsen

ICO reference: ZB973463

What information we collect, use, and why:

We collect or use the following information to provide client care and meet our ethical responsibilities

Name, address and contact details
Gender
Pronoun preferences
Date of birth
Next of Kin details including any support networks
Emergency contact details
Health information (including medical conditions, allergies, medical requirements and medical history)
Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)
Insurance policy details
Records of meetings and decisions
Information about income and financial needs for reduced fee status

We collect or use the following personal information for the prevention, detection, investigation or prosecution of crimes:

Name, address and contact details
Video recordings of public areas (including corridors, waiting rooms and outside spaces to which some or all members of the public have access)

We collect or use the following information for safeguarding or public protection reasons:

Name, address and contact details
Emergency contact details
Records of meetings and decisions

We collect or use the following personal information to comply with legal requirements:

Name
Contact information
Safeguarding information

We collect or use the following personal information for dealing with queries, complaints or claims:

Names and contact details
Addresses
Payment details
Video recordings of public areas
Customer or client accounts and records
Information relating to health and safety (including incident investigation details and reports and accident book records)
Correspondence

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legitimate interests - we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Some information is needed to allow Freedom Psychotherapies to provide a safe and ethical Counselling and Psychotherapeutic service. This includes records kept on use of medication, diagnosed or suspected health conditions as well as session notes as required by the BACP, COSCA and insurance. Information is needed for safeguarding both for the client, vulnerable adults and children where risk of harm is suggested. Contact information may be needed to be shared with legal bodies on receipt of a court mandate or where information is shared under The Terrorism Act 2020 or The Proceeds of Crime Act 2002

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for the prevention, detection, investigation or prosecution of crimes are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for safeguarding or public protection reasons are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information to comply with legal requirements are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Where we get personal information from

Directly from you
Family members or carers
Other health and care providers
Third parties:
Schools, Colleges, or Universities
Client and referral agencies

How long we keep information

Information is kept for 7 years from the date of contact (7 years from your 18th birthday if Counselling begins before this date)

Information is kept in a locked filing cabinet, this might include being saved on an external hard drive, or on a laptop. Laptops will be password protected and stored in a locked filing cabinet when not in use.

After 6 years (or 6 years after your 18th birthday) all data will be destroyed.

In event of my death all data will be destroyed as per a professional will. It may not be possible to inform you that this has occured.

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint