Your privacy is of great importance to me and I, Hannah Raine-Smith, The Portable Therapist (TPT) am committed to complying with the terms of the General Data Protection Regulation (GDPR) regarding the responsible and secure use of your data.
I have a legitimate interest in processing personal data in order to provide psychosocial services. The purpose of this statement is to let you know what personal information I collect and hold, why this data is collected, how long it is kept and what your rights are with regards to this personal data. I am registered with the Information Commissioners Office (ICO).
When you are referred for psychosocial services with me you will be asked to consent to the processing of your data under the terms of this policy. I will also be responsible for my own data management, will abide by this privacy statement, and will hold my own privacy statement that complies with the GDPR terms.
What information does TPT collect?
I collect personal data such as name, address, date of birth, gender, GP/medical practitioner details, deployment details, employer’s details, telephone numbers, email address and Skype address. I also collect any data you give me regarding personal and family background, alongside potentially sensitive data relating to medical and mental health conditions.
What does TPT use your information for?
I use your information in the following ways:
· To provide clients with psychosocial services requested from TPT.
· To notify you about changes to your appointments and the services I provide.
· To fulfil any administrative, legal, ethical and contractual obligations.
· On occasion I will provide information on trainings, workshops, blogs, electronic mailings or newsletters specific to TPT services only.
What information does TPT share?
I will not share any information about you with other organisations or people, except in the following situations:
· Consent – I may share information with relevant medical professionals or others whom you have requested or agreed we need to contact.
· Serious harm – I may share your information with the relevant authorities if we have reason to believe that this may prevent serious harm being caused to you or another person.
· Compliance with law – I may share information when the law requires us to - i.e. safeguarding, terrorism, drug trafficking and serious crime.
· Clinical Will– I have a clinical will which means in the event of sudden death or a serious accident or illness, a named colleague will be able to access the contact details so we can notify clients.
· Supervision– It is an ethical requirement for any clinician offering psychosocial services to have regular supervision. Any supervisor used is an accredited member of the relevant accrediting body and works within their ethical framework.
How does TPT keep your information safe?
· All information you provide to THT is stored as securely as possible. I will take all reasonable precautions to prevent the loss, misuse or alteration of information given.
· All paper forms and correspondence are kept in locked filing cabinets. All electronic files are kept on password-protected devices with virus protection software.
· Formal reports are password protected and/or they are sent through a secure encrypted service such as Protonmail.
· If process notes are made they are kept separate from any identifiable personal information.
· For live chat or audio-webcam appointments, wherever possible, I use Skype or Zoom which feature end-to-end encryption for added security.
· Whilst I endeavour to keep our systems and communications protected against viruses and other harmful effects, we cannot bear responsibility for all communications being virus free.
· Client notes and other documentation are destroyed seven years after the end of the psychosocial services offered.
· Any known data breaches will be reported to the ICO within 72 hours.
· Any requests for personal data need to be made through a data subject access request and will be supplied within one month.
· THT’s website, www.theportabletherapist.com, is maintained by Wix.
· If clients choose to contact TPT by text or mobile phone, numbers are stored under a reference system and/or initials only, as opposed to full names.
Under the GDPR, you have the right to:
· Access your personal data - Rectify, erase or restrict your data - Object to the processing of your data - Request transfer of data (data portability).
· You may withdraw your consent for TPT to hold and process your data at any time. However, if you do this while actively receiving psychosocial services, the services would have to end. You can withdraw your consent by stating this on an email to email@example.com
· If you have any concerns about the way TPT handles your data please contact firstname.lastname@example.org. If you feel this has not been resolved effectively you have the right to contact the Information Commissioners Office (www.ico.org.uk)
Changes to this policy
This document is a work in progress and may be modified from time to time.