Privacy Policy

Introduction
Your privacy is held with the utmost importance within my practice. I will endeavour to keep your personal data and information safe and secure. Your data will only be used for the purpose that it was given to me. I adhere to the General Data Protection Regulation (GDPR - EU/2016/679), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003. 

All personal information that you provide is held within the aforementioned regulations or acts. At any time, you have a right to see any of this information. Any requests made to view any personal data or information that I hold regarding you, will also be noted and recorded.

About Will Hardy Therapy

Will Hardy Therapy is a private therapeutic practice working in-person within London and online. I am a registered data controller with the Information Commissioner's Office. My registration number is: ZB548646 

How your information is collected

Your information is collected through any correspondence i.e., emails, SMS, phone calls or within our sessions.

What information may be collected

As part of your assessment and completing the forms necessary to begin our therapeutic work, some of the following information may be captured. To note, some information may not be applicable to you or you may wish to not disclose parts. 

  • Your full name

  • Your age and date of birth

  • Your gender or preferred identity

  • Your sexual orientation

  • Your race or ethnicity

  • Your disabilities

  • Your religion, faith or beliefs

  • Your medical conditions

  • Your prescribed medication 

  • Your relationships and/or progeny

  • Your occupation

  • Your history of previous counselling or psychotherapy experience

  • Your issues, challenges and difficulties 

  • Your home address

  • Your mobile phone number

  • Your email address

What information is stored

The following list outlines the documents, files or items that will include your personal information or data which is securely stored (see below). 

  • Brief session notes either within electronic Google docs or physical notepads

  • Brief supervision notes either within electronic Google docs or physical notepads

  • Signed client agreement form (contract) which will either be filled out electronically or physically on printed paper

  • Contact information i.e., phone number, email address, GP details

  • Any correspondence via emails, SMS or phone calls

  • Signed GDPR / Privacy Policy agreement

  • Assessment records either within electronic Google doc or physical print outs

  • If requested, and with full consent, recordings of sessions or written case studies (all anonymised)

How your information and data is stored

Any information or data collected from you may be stored across the following mediums:

Laptop / smartphone: Information will be stored in mobile apps that are password protected and encrypted. Data will also be backed up to my Google Drive which is also password protected. The amount of apps I use is kept to a minimum. 

Correspondence: Any information pertained from email, SMS or phone calls (logs) will be stored within the relevant smartphone apps. Your number may be saved within my mobile phone book. Emails are currently handled through Gmail.

Website: My website (www.willhardytherapy.com) is hosted through SquareSpace. I use their website analytics service to collect standard internet log information and details of how visitors access and use my website. If someone visits www.willhardytherapy.com, this information is non identifiable and is only processed to understand the efficacy of the website. Please view Squarespace’s privacy policy for more information: https://www.squarespace.com/privacy 

Notes: Any written notes I make are stored safely and securely in my home. This also applies to any physical papers we may use in session.

Google Meets: I use Google Meets to host online sessions. Data used in this instance will be your email address for calendar invites and to join the session. Please view Google Meet’s privacy policy for more information: https://policies.google.com/privacy?hl=en 

How your information may be shared

In the event of an emergency, I may share your contact information with emergency services i.e., the police, ambulance services or mental health teams. Additionally, if I feel you may be in danger, I may make contact with your GP. Where possible, this is upon the basis of receiving your consent. 

If you have disclosed information regarding your involvement in terrorist activity, money laundering or serious crimes, past or present, the law may require me to share your personal information without your consent or permission. This extends to causing someone harm with intent. 

If you become involved in a court case, the court may subpoena session records or data that I hold about you. I must comply with this, by law, however, I would attempt to contact you in the first instance. If you’re aware of a court hearing or case that you’re involved within which may need to involve me, please contact me informing me of this. I will not confirm your name, details or our therapeutic engagement if I am contacted unless I have your consent to do so. 

As part of my regular supervision, I discuss practice, session and client material. This is within a professional agreement with a qualified counsellor, supervisor or therapeutic consultant. Any information or details will be anonymised, non-identifiable, brief and discussed verbally to provide my practice and professional processes with ethical and adequate support. The qualified counsellor, supervisor or therapeutic consultant I engage with is also bound to the same or similar ethical frameworks and agreements of confidentiality. 

In the event of a personal emergency where I am unable to work or in the event of my death, the terms within my Therapeutic Will shall be actioned. Therefore, your first name and contact information will be shared with my Therapeutic Executors. This course of action will only take place if you are within counselling with me, at the time, and for you to be informed of my professional incapacity or death.

Deletion of your information

In accordance with my liability and indemnity insurance and GDPR, I must keep any session records or personal information for seven years after the final date of our therapeutic engagement. After this time, all information and data will be shredded or deleted electronically from all apps, drives and back ups. 

This information will only be used for case study purposes (with your consent and to be discussed) or to consult, if you return to counselling after completion of our therapeutic work. 

Your rights

Within GDPR legislation, you have the following rights to your information within our therapeutic engagement:

  • The right to information - you have the right to be informed about the information and data I hold, as outlined, within this document.

  • The right to access - you have the right to view the information that I hold in regards to you. Please note, the first request to access your information is free, however, any requests after this will be charged a fee for administration costs.

  • The right to rectification - you have the right to change, amend or clarify any incomplete or inaccurate information that I hold in regards to you.

  • The right to erasure - you have the right to request deletion of all personal information that I hold about you. However, on some occasions, I can decline this request if the information or data being held is essential for me to practice ethically, competently and lawfully. 

  • The right to restriction of processing - you have the right to restrict the use and processing of personal information that I hold about you. However, there are some limitations within this request. See more below.

  • The right to data portability - you have the right for your information to be shared between data controllers within commonly used formats. 

  • The right to object - you have the right to object to your data and personal information being processed. However, there are some limitations within this request. See more below.

  • The right to avoid automated decision-making - you have the right to not be subject to decisions being made solely based on automated processing.

For more information regarding your rights, under GDPR, please see more on the following link:

https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

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