1. Introduction
Sean Humfrey Counselling is committed to protecting your privacy and handling your personal information with respect, care and confidentiality.
This Privacy Policy explains how I collect, use, store and protect personal information when you visit my website, make an enquiry or receive counselling from me.
I am the data controller for the personal information processed in connection with Sean Humfrey Counselling. I handle personal information in accordance with applicable UK data protection law, including the UK GDPR, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR), where relevant.
Contact details
Sean Humfrey Counselling
Meadowsweet, Great Glemham, Suffolk, IP17 2DB
Email: sean@seanhumfreycounselling.com
Telephone: 07853 247768
Website: www.seanhumfreycounselling.com
2. Personal information I collect
The information I collect depends on whether you are visiting the website, making an enquiry or receiving counselling.
Contact and identification information may include your name, email address, telephone number and correspondence. I will collect emergency contact details (phone number) and contact details for your G.P.
Counselling information may include personal history and background, information about your emotional and psychological wellbeing, relevant physical health information, relationships and personal circumstances, information discussed in sessions, assessments, professional observations and session notes. Some of this information is special category personal data, particularly information about physical or mental health.
Website and technical information may include your IP address, browser and device information, pages visited and information about how you use the website. The information collected will depend on the website technologies and settings in use.
3. How I collect information
I may collect information when you contact me by telephone or email, submit the website contact form, provide information during an initial consultation or counselling session, communicate with me by email or WhatsApp, or take part in an online counselling session using Google Meet or WhatsApp video. Website technologies, including cookies and similar technologies, may also collect technical information.
Please do not include detailed or highly sensitive personal or health information in an initial website enquiry. We can discuss what information is needed and an appropriate way to share it if we arrange an initial conversation.
4. How I use information
I use personal information to respond to enquiries; arrange initial consultations and appointments; consider whether counselling is suitable; provide and manage counselling; maintain appropriate professional records; communicate about appointments and changes; meet professional, legal and ethical responsibilities; administer payments and accounts where applicable; maintain website security and operation; and handle complaints or legal matters where necessary.
I do not use counselling information for unrelated marketing. I will not send marketing communications unless I have an appropriate lawful basis and, where required, your consent.
5. Lawful bases for processing
I must have a lawful basis under Article 6 UK GDPR for processing personal information. Depending on the purpose, this may include:
· Contract (Article 6(1)(b)): to take steps at your request before entering into a counselling agreement and to provide the agreed service.
· Legitimate interests (Article 6(1)(f)): for appropriate practice administration, record management, service security and the establishment, exercise or defence of legal claims, where these interests are not overridden by your rights.
· Legal obligation (Article 6(1)(c)): where processing is necessary to comply with a legal obligation.
Counselling involves the sharing and processing of personal information that may include sensitive information about your physical and mental health, personal relationships, sexual orientation, beliefs and other aspects of your private life.
Some of this information is classified as special category personal data under UK GDPR and receives additional legal protection.
I process this information only where an appropriate condition under Article 9 UK GDPR applies, together with any additional requirements under the Data Protection Act 2018.
For confidential counselling, advice and support, this may include Article 9(2)(g) UK GDPR, read alongside Paragraph 17 of Schedule 1 to the Data Protection Act 2018, where the specific statutory requirements are met.
Where appropriate, other applicable conditions may also be relied upon, depending on the nature and purpose of the processing.
I take particular care to ensure that sensitive information is collected and retained only where necessary, is treated confidentially and is protected through appropriate security measures.
6. Confidentiality and when information may be shared
Confidentiality is fundamental to the counselling relationship. I will normally keep information you share confidential and will not disclose it to another person without your permission.
There may be circumstances in which confidentiality must be considered alongside legal, safeguarding or serious-risk responsibilities. Examples may include a serious risk of significant harm to you or another person; concerns about the safety or welfare of a child or an adult at risk; a legal requirement or court order; or a situation in which disclosure is necessary to protect someone's vital interests.
Where it is reasonably possible and appropriate, I will discuss a proposed disclosure with you first. If that is not possible or appropriate, I will act in accordance with my legal and professional responsibilities. I will aim to share only information that is relevant and necessary, and will document significant decisions about disclosure.
7. Professional supervision
I undertake professional supervision as part of my counselling practice. Relevant aspects of my work may be discussed with my supervisor to support safe, ethical and effective practice.
I will anonymise information wherever possible so that you cannot be identified. If identifiable information needs to be discussed, I will take appropriate steps to ensure that confidentiality and data protection safeguards are in place and that the disclosure is justified.
8. Services and systems I use
Squarespace: My website is hosted using Squarespace. Information submitted through the website contact form and technical information generated when you visit the site may be processed by Squarespace in providing its services.
Google Workspace: I use Google Workspace for professional email and associated administrative activities. Information contained in emails and related services may be processed by Google.
Online counselling: I may provide online counselling using Google Meet or WhatsApp video. These services process information needed to establish and operate the online connection. I do not routinely record counselling sessions. If recording were ever proposed, this would be discussed separately in advance and would only take place where there was an appropriate justification and safeguards.
WhatsApp: I may use WhatsApp for appointment arrangements and, where agreed, video counselling. I aim to keep administrative messages brief and avoid using ordinary messaging for detailed counselling notes or unnecessary sensitive information. Please consider whether WhatsApp is suitable for your own privacy needs before using it to contact me.
Paper and electronic records: I keep relevant practice records in paper and electronic formats. I take appropriate steps to protect records against unauthorised access, loss, alteration or disclosure, and restrict access to those who need it for practice purposes.
Online Sessions: Online Sessions with be via WhatsApp. Recording sessions is forbidden. WhatsApp are a third party data processor and may collect data such as IP addresses, names, email addresses and phone numbers.
Third-party providers may process information on my behalf. I take steps to understand the providers' privacy terms, contractual arrangements, security features and any relevant international data transfer arrangements. The providers' own terms and privacy notices also apply to their services.
9. How long I keep information and how I store it.
I keep personal information only for as long as it is reasonably necessary for the purpose for which it was collected, taking account of legal requirements, professional responsibilities, insurance requirements and the need to establish or defend legal claims. I keep data such as clinical notes and client documents. for a period of 7 years. Brief session notes are stored anonymously on paper in a locked filing cabinet. Electronic notes and information is stored on a password protected computer which is kept in a secure locked room. Your signed agreement is stored separately in locked cabinet or separately on a password protected computer. Your email address will be stored on my email account and I use Google Workspace cloud service (password protected) to back up my computer and android phone. My phone is password protected.
When information is no longer required, I will securely delete it or destroy it.
10. International transfers
Some providers used in operating the website, email or online counselling services may process or store information outside the United Kingdom. Where personal information is transferred internationally, the provider and I must ensure that an appropriate legal transfer mechanism and safeguards are in place where required by data protection law. Further information about a provider's arrangements can be found in its privacy and data protection documentation.
11. Your data protection rights
Depending on the circumstances, you may have the right to request access to personal information I hold about you; ask for inaccurate information to be corrected; request erasure; request restriction of processing; object to processing; and request data portability.
These rights are subject to legal conditions and exemptions. For example, I may not be able to delete information where I have a lawful reason or obligation to retain it. Counselling records may also contain information about other people, or material subject to applicable exemptions.
To exercise a right, contact me using the details in this policy. I may need to verify your identity before responding. I will respond within the time limits set by data protection law.
12. Complaints
If you have a concern about how I handle your personal information, please contact me first using the details above. I will take your concern seriously and seek to address it.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data protection regulator: https://ico.org.uk/make-a-complaint/.
13. Changes to this policy
I may update this Privacy Policy to reflect changes in my practice, the services I provide, the systems I use or applicable law. The current version will be made available on my website.