Privacy Policy 1 — Jellyfish-Counselling

Jellyfish-Counselling Website Privacy Policy

Contact Details:

Name: Izzy Sturgess

Phone Number: 07562334560

E-mail: izzy.sturgess@jellyfish-counselling.co.uk

The type of personal information I collect

· Personal identifiers, contacts, and characteristics (for example, name and contact details)

· Financial information such as name of payee which will show on my bank statements when clients/payees have paid for sessions. My bank statements are protected by a two-factor authentication system on my banks website. Should a refund need to be issued in the event of overpayment, I will ask for your bank details to return said payment and will then delete the provided information

How I get the personal information and why I have it

Most of the personal information I process is provided to me directly by you for one of the following reasons:

· To respond to enquiries made through online mediums such as website, email, voicemail and text message, including social media (Facebook, WhatsApp and Instagram) and telephone

· To organise appointments, answer queries and any other necessary activity that allows me to effectively carry out my counselling practice

I also receive personal information indirectly, from the following sources in the following scenario:

· Website host Squarespace analytics, including area location and IP address. More information on their GDPR policy can be found here: https://support.squarespace.com/hc/en-us/signin?return_to=https%3A%2F%2Fsupport.squarespace.com%2Fhc%2Fen-us%2Farticles%2F360000851908-GDPR-and-Squarespace

I treat all information provided to me as confidential with certain limitations, such as if I deem you to be of significant risk to yourself or others, or if another person you mention is at significant risk. I will endeavour to discuss this with you in a session and may seek permission from you to contact your GP or another party should that action help to safeguard you or another person, including someone under the age of 18. This may not always be possible, for example if I deem you or or another person to be in immediate danger then I maintain the option to break confidentiality in accordance with the British Association of Counselling and Psychotherapy of which I am a registered member ( https://www.bacp.co.uk/events-and-resources/ethics-and-standards/ethical-framework-for-the-counselling-professions/confidentiality/ ). This also complies with vital interests under GDPR, as would be lawfully processing the data in order to protect a person’s life. I am also required by law to report information which could aid the prevention of terrorist activities and drug money laundering to the appropriate party.

I attend monthly clinical supervision in accordance with the British Association of Counselling and Psychotherapy ethical framework, for which I am enlisted as a demonstration of my ethics and use of best practice. I occasionally use data collected for academic work such as case studies, for which I will obtain your written permission first. All personal information will be anonymised. I may also use anonymised cases for the use of peer and clinical supervision which falls under “a contractual obligation for processing” in accordance with ICO stipulations, as I have an ethical obligation to complete supervision as per my membership with the British Association of Counselling and Psychotherapy.

The individuals using my service have a right of access to the data I hold regarding you, as per ICO protocol. A “freedom if information request” needs to be submitted to me in writing, of which I have up to one month to provide you your information, and a meeting will be held after this day to discuss the provided information, as it can be used as a chance for the data requester and data controller to discuss any necessary points and findings. Should a request be deemed “excessive or unfounded”, then an “appropriate” fee will be charged.

All individuals under GDPR linked to Jellyfish-Counselling have a right to have their data “erased or forgotten”. This also includes said individuals being able to request their data be amended if they feel it does not adequately represent them or their experience. This can be denied by the data controller in the event of legal processing requirements as stipulated above. Should any dispute between an individual and data controller take place about the data recorded that cannot be resolved by mutual agreement, that dispute will also be recorded alongside the existing data as a reflection of both parties having attempted to resolve said dispute.

I sometimes use reviews and testimonials on my website, Facebook, Instagram and advertising platforms such as directories, leaflets and business cards as a means of marketing for new clients. Testimonials and reviews are not mandatory and whether I ask for feedback or it is provided freely, I will seek recorded consent from the client to use this for marketing purposes described above. All published testimonials and reviews will be anonymised to protect confidentiality, which could include removing first names and any other identifying information.

Please note the internet is not entirely secure and I can only make best endeavours when it comes to the security of your data when using this website, therefore use of this website is to be considered as under the visitors or users own risk. In the event of a data breach, I am required to notify the ICO.

How I store your personal information

Any other information which you provide, for example in enquiries and session content will be stored for six years from the date counselling finishes or the date I last have contact with you, and then paper copies will be shredded and electronic files deleted. This is so that I am in accordance with ICO’s stipulations on data processing, and that I have the relevant information available in the event a complaint is made about me as a practitioner, as there is a six-year timeframe for which legal action surrounding the counselling can be brought.

Information recorded on paper is kept in a separate safe locked by key. Any electronic information is kept on my business laptop, which is password protected, or my business phone which is also password protected. If you progress with counselling sessions, a copy of this form will be sent to you to sign, and it will include a section on obtaining consent to store phone numbers in my business phone for the purpose of telephone counselling and organising appointments where applicable, for the length of time that the counselling takes place. Email addresses are retained in Outlook associated to my email accounts izzy.sturgess@jellyfish-counselling.co.uk and isturgess.counselling@outlook.co.uk. Please see their website for an explanation of how they operate in accordance with GDPR: https://learn.microsoft.com/en-us/compliance/regulatory/gdpr

In the event that texts, voicemails, emails or enquiries made by social media (Facebook, Instagram and WhatsApp) and my website contain sensitive information, which may be required for current or future legal compliance or potential legal action brought against Izzy Sturgess of Jellyfish- Counselling, these will be documented and kept either in a secure locked filing cabinet or electronically on my work laptop for six years from the last date of contact for people aged eighteen or over. For people aged seventeen and under, said data will be retained for six years after a child’s 18th birthday, then destroyed as appropriate based on the media type the data is stored in accordance with.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at izzy.sturgess@jellyfish-counselling.co.uk or 07562334560.

You can also complain to the ICO if you are unhappy with how I 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

ICO website: https://www.ico.org.uk