Privacy
Privacy Notice
Free to Be provides Counselling and Psychotherapy, Content Writing and Training Services to individuals, groups and organisations. To carry out these services, Free to Be processes and stores personal data. This Privacy Notice explains how we use and store your data, in line with the General Data Protection Regulations (GDPR) May 2018, and the Data Protection Act (DPA) 1998.
What type of Personal Information Free to Be Holds:
The personal information we process is provided to us directly by you via contact from the Free to Be website, via SMS or email and from information disclosed in Counselling sessions.
Personal information gathered by Free to Be may include:
Personal identifiers, contacts and characteristics (for example, name and contact details).
Date of birth.
Offences, criminal convictions and alleged offences.
Emergency Contact information.
Relevant medical details and GP contact details.
Details of support services accessed in addition to Free to Be
Financial Data, including date and amount of payments.
Attendance information.
Brief and factual, anonymised notes summarizing the focus are also produced following each Counselling session. These are stored separately from any identifying information.
Why Does Free to Be Gather, Process and Store Your Personal Information?
Personal Information is gathered by Free to Be for the purpose of meeting the contractual agreement of providing a safe and ethical service and to comply with Safeguarding and Legal Responsibilities.
How Free to Be Gathers, Processes and Stores Your Personal Data:
Free to Be is registered with the ICO adheres to the GDPR laws and regulations as set out at www.ico.org.uk.
Personal data is gathered, processed and stored with client consent.
Personal data is stored within secure, lockable filing cabinets, with personally identifying information stored separately from session notes. SMS messages are stored on a password protected mobile phone and emails are stored on a password protected laptop with up to date Antivirus software.
On the conclusion of Counselling, all personal data is stored for the duration of five years as required by Free to Be’s Insurance Provider, and in line with the BACP. After this, Free to Be will dispose of your information by securely shredding and deleting digital data.
Financial data:
Free to Be Counselling will not store client bank details on any forms or paperwork, other than the payments made via bank transfer. On the occasion where refund and payment details are provided via SMS or e-mail, this will be deleted after payments are made.
Sharing of Personal Data:
Your data will not be shared with a third party without your consent. The only time this is overruled is when required by law to do so or where there are Safeguarding concerns about a child or a vulnerable adult, or where you or others are at serious risk of harm. In such instances, only the minimum required data will be shared.
Clinical supervision as per BACP Ethical Framework:
The British Association of Counsellors and Psychotherapists (BACP) require all BACP registered counsellors to access clinical supervision each month. I adhere to the BACP Ethical Framework and will therefore discuss anonymised details of Counselling provided by Free to Be with my Clinical Supervisor. This is for the purpose of ensuring safe, ethical and effective practice and to monitor due diligence and duty of care to Counselling clients.
My clinical supervisor has been instructed on my behalf to enact a clinical will in the event of my sudden death or my incapacitation. Under the terms of this will, my supervision has been given permission to access contact details for my counselling clients to inform them of my demise / incapacitation and to offer to provide counselling as needed.
Consensual Information Sharing with Third Parties:
Free to Be will consider sharing data where the client consents to a release of data and where Free to Be assess that to do so is in the best interest of the client.
When Counselling is being organised via a Third Party, e.g., an employer, there may be an expectation for Free to Be to share attendance information with the Third Party. Where this is a requirement, Free to Be will discuss this with you prior to entering into a Counselling Agreement, and such information will only be shared with your consent.
Your Data Protection Rights:
Under data protection law, you have rights including:
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
Free to Be Counselling is committed to being transparent about the data it collects and how you can exercise the right to access this information at any time. This may be done by e-mailing Free to Be Counselling a ‘data subject access request’. You are not required to pay any charge for exercising your rights. If you make a request, Free to Be will initially confirm receipt of your request, before then responding comprehensively within 28 days.
Please contact us at Claire@freetobecounselling.org if you wish to make a request.
How to Complain
If you have a concern or complaint about Free to Be’s use of your Personal Data, you can share your concerns by emailing Claire@freetobecounselling.org where you can expect an initial acknowledgement reply and then a more comprehensive response within 28 days.
You can also complain to the ICO if you are unhappy with how Free to Be have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Privacy Policy Review
The privacy policy and terms and conditions are subject to change from time to time in compliance with any changes in law, regulation, and guidelines from the ICO or BACP framework. The planned review for this policy is May 2024.