This privacy notice sets out how DCC uses and protects any information that you give us when you visit this website or when you contact us by other means and the lawful basis under the Data Protection Act 2018 and the General Data Protection Regulation (‘GDPR’) that permits us to do so.
Children and young people under the age of 16 must have the consent of their parent, guardian or carer in order to contact us via the website or by phone.
Consent to hold your personal data
DCC is committed to ensuring that we protect your privacy and will seek your explicit written consent to hold personal data about you, specifically and only for the purposes of providing counselling to you. We may also analyse data you provide us with for the purposes of providing the best possible service to you.
If you make contact via this website or by phone you will be asked to provide certain information by which you can be identified (see below).
You can be assured that all this information is held securely and will only be used in accordance with data protection principles, our data protection and confidentiality policies. In addition, DCC is an organisational member of the British Association for Counselling & Psychotherapy (BACP) and adheres to the BACP Ethical Framework for Good Practice. We will honour the confidence and trust you have placed in us.
The basis on which we hold or share information about you is outlined below and also the limits around confidentiality.
You have the right of access to information we hold about you and to amend or ask for deletion of information that may not be accurate or correct. Please contact us if you wish to view the data we hold about you. DCC will not hold your data for longer than is deemed necessary for the purposes of counselling and following best practice and legal guidance. If you wish to know how long we hold data or notes for please contact us.
By visiting our website you are agreeing to the contents of this Privacy Notice.
For the purpose of the Data Protection Act 2018 and the GDPR, the data controller is Dover Counselling Centre, Horizon House, Gordon Road, Whitefield, Dover, CT16 2EP. You may also contact our Data Protection Officer via email@example.com
The types of personal data we collect and use
Whether or not you become a client of our counselling service we’ll use your personal data for the purposes of initiating counselling for you. We collect the majority of this information during first contact and assessment. We will advise you if any of this data is optional.
At first contact
We will collect the following information in order to establish if we can provide you with counselling:
- Your name
- Your gender
- Date of birth
- Contact information including your telephone number, address and email
- Other information relevant to you engaging in counselling with us, e.g. the name of your medical practice, any log-term conditions you may have and details of any medication you are taking
- Information about any disability or communication difficulty you may have
- At first contact you may also choose whether or not to share with us a brief description of what is bringing you for counselling now
- Information about your income level to establish the cost of your assessment
- Information about your education or employment status
- If applicable, details of your military service
- At assessment you will be asked to sign our Informed consent form to give us permission to process your data and also information about your healthcare professionals and emergency contact details
- Anonymised counselling notes – your identity is protected and these notes are not shared with anyone unless we are legally required to do so or the client specifically requests we share them with another third party, which we have the right to refuse to do
- Personal data that identifies you and counselling notes are held separately and securely to protect your anonymity
- You have the right to view these notes and you would be advised of any request to share your notes
- These notes are the property of DCC and not the client
- Only your counsellor or in exceptional circumstances, i.e. in order to protect you or your counsellor, the Clinical Lead is authorised to access your notes
What we do with the information we gather
We collect this information to understand your clinical and other needs from counselling and provide you with a better service, and in particular for the following reasons:
- internal record keeping
- to assist with clinical assessment, allocation to an appropriate counsellor and for professional supervision of how we work
The lawful basis and purpose of holding this data is to ensure we can meet the terms for providing a contract for counselling with you. It is also to ensure good governance and for our own legitimate interests as a charity ensure we meet the requirements of our social mission.
We will also use your personal data to meet any legal obligations placed upon us – for instance when you exercise your rights to see what data we hold under data protection law or in order to meet any legal compliance placed on us; or occasions where we may be obliged to disclose information related to safeguarding children, young people and adults at risk.
Your written consent will be sought at assessment for the need to meet possible disclosure to other bodies and for when we process any special categories of sensitive personal data about you, such as gender, sexual orientation or biometric data, (when processed data is anonymised).
Where we store your personal data
The data that we collect from you is not transferred outside the European Economic Area (“EEA”).
DCC will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice and our data protection and confidentiality policies.
All information you provide to us is stored securely and information held on computer is held on our secure servers.
Unfortunately, the transmission of information via the internet cannot be completely secure. We have in place security measures to protect your personal data, but we cannot guarantee the security of your data transmitted to our site, particularly by email; any transmission is at your own risk. Once we have received your information, we will use our own policies and procedures as far as is reasonably possible to prevent unauthorised access.
DCC is committed to making sure your information is secure. We have in place appropriate policies and procedures to prevent unauthorised access or disclosure. There are suitable and appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Links to other websites
Our website contains links to other websites that may be of interest. However, DCC has no control over other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at their privacy statements
Controlling your personal information
We do not share your personal information with anyone else unless in pursuit of counselling on your behalf and only then if we have your permission to do so. In exceptional circumstances we may be required by law and our ethical responsibilities to break our confidentiality with you.
We would discuss this with you first wherever possible but if you do not give consent we may still have to disclose information. This relates to situations where you may be at risk of harm, causing harm to others, the safeguarding of children, young people and adults at risk, acts of terrorism and unreported road traffic accidents where we are under legal obligations.
Access to information
You have the right of access to the personal information which we hold about you under the Data Protection Act 2018 and the GDPR and also the right of access to your client notes. You can contact us or email us if you wish to examine what we hold and believe that any information we are holding on you is incorrect or incomplete. Steps will be taken to correct any incorrect information that we hold.
There is no charge to access this information and it will be provided to you within one week unless circumstances require longer, but this will not exceed a month in any event.
You have the right to complain to the Information Commissioners’ Office in connection with enforcement and compliance with data protection law at www.ico.org.uk
Questions, comments and requests regarding this privacy notice, policies and procedures around privacy and confidentiality are welcomed and should be addressed to us by email to firstname.lastname@example.org or by writing to us at our address.
The intention of this procedure will always be to deal with complaints as swiftly and confidentially as possible.
Raising a complaint or concern
If you have a concern or complaint about our service, please speak to a member of staff who will try to help you if they cannot assist you will speak to someone else who can deal with your concern.
If you would find it easier to email your complaint the please send your email to the following address email@example.com
We will always try to resolve your issue informally first.
What will happen of you raise a concern or complaint?
If we are unable to resolve your issue informally and you decide to make a formal complaint, then this will be acknowledged in writing within five working days.
We will fully investigate your complaint which may involve a discussion with you.
We aim to investigate and respond to all complaints as soon as reasonably practicable and aim to send you a written response within 28 working days. Although this may vary depending on the
complexity of your complaint.
What if I am still not happy?
If you feel that your complaint has not been resolved to your satisfaction, then you should let the Chief Executive know in writing. Your complaint will then be reviewed by the Chairman of the Board of Trustees or his delegated representative.
If you are dissatisfied with the Chairman’s response, then you can take the complaint to the following organisations. But please note that they can only investigate your complaint once it has
been investigated by us.
For NHS Improving Access to Psychological Therapy (IAPT) complaints You should address your complaint to the Parliamentary and Health Service Ombudsman. The Parliamentary and Health
Service Ombudsman makes final decisions on unresolved complaints about the NHS in England. For further information, please visit: https://www.ombudsman.org/making -complaint.
For non NHS services we provide then it should be addressed to: British Association for Counselling and Psychotherapy (BACP)