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Data Protection (GDPR) and Confidentiality

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When we work together I collect personal information from you to help me provide safe and effective therapy. In handling this information, I am bound by the General Data Protection Regulations (GDPR). This page will explain how this affects the way I work.

If you have questions about any of this, please discuss them with me before booking a session, or at a session you have already booked.

 

Protecting your personal information:

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  • Horbury Integrative Therapies is my own company.

  • As I am the only person who works for the company I am both the Data Controller and the Data Protection Officer. My contact details are; Catherine Frampton, cate.frampton@gmail.com 07828159602

  • In most cases, the information about you that I collect comes from you, via an email, phone call, online form or during our online sessions.

    • If you are under 18, I may get some information from your parents or school.

    • If you are referred by someone else (e.g. an employer) I may get some information from them. 

    • If you make a purchase via paypal, they will send me your contact details so I can send you what you've bought. All PayPal transactions are subject to the PayPal Privacy Policy

  • I use your personal data in the following ways

    • to provide you with items you have purchased, e.g. audio downloads

    • to deliver therapy

    • to reply to you if you contact me with questions about my services

    • to contact you between therapy sessions if necessary

    • to allow me to collect payment from you, and maintain my records and accounts

  • You have no legal requirement to share any information with me, but if you do not do so I will not be able to work with you. 

  • The categories of data/information I collect include: your name and contact details, your medical history, your family situation and support network, the nature of your employment, your hobbies and interests, your lifestyle, and details of the problem you’d like me to help with. These details are necessary to provide you with safe and effective therapy.

  • The lawful basis of my collecting and processing data is consent or contract or legitimate interests. You consent to my holding and using your information when you submit an online form. Clicking a paypal button creates a contract to supply goods or services which I cannot do without using your data. If you undertake therapy with me you will sign my terms and conditions, which creates a contract. If you email, phone or contact me via social media with enquiries it is a legitimate interest of my business to use your contact details to reply to you

  • Sharing information:

 I am the only person who has access to your information unless

  • there is a legal requirement for me to share the information (e.g. a court order or warrant is issued)

  • you ask me in writing to share your information with someone else

  • I am working with you as part of a care team, or you have been referred to me by someone else (e.g. an employer), in which case pre-arranged levels of information will be shared with these relevant parties 

  • I keep the information you give me for seven years, which is the length of time required by my insurance company. After this time it is shredded and disposed of securely. 

  • You have rights over the information I hold about you. These are

    • Portability - you can ask me to send your information to someone else

    • Rectification - if you think my records are wrong you can ask me to change them

    • Erasure - in some circumstances you can ask me to remove your details from my records (this is sometimes called 'the right to be forgotten')

    • Fair profiling - you can ask that any processes I automate are done by a person instead of a computer. I don’t automate any information processing, although I do use online forms to collect information. If you prefer not to complete these, the information can be collected face to face at our first session.

    • Right of access - you can have a copy of the information I hold at any time, by requesting it in writing. If you do this it will be provided within 30 days and free of charge.

    • Restricting processing - in some circumstances you can request that I stop processing your information

    • Objection - you can object to the way I process information (e.g. if it is used to send you direct marketing you don’t want to receive) and you can ask me to stop using it in that way

    • Information - you have the right to understand how I collect and process your information (hence this privacy notice) 

  • If you are under 18 I will need permission from a parent or guardian before working with you, and if you are under 13 I will need to verify your date of birth.

  • You can learn more about these rights on https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/  

  • You can withdraw your permission for me to use your information at any time, this means ending your therapy. 

  • You have a right to complain to the ICO if you have any problem with the way I store or use your data, or if you do not think your rights are being respected. 

 
 

Social Media

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Most businesses encourage their clients and customers to connect with them and to discuss their products on social media and other web based discussion forums. It's a bit different for therapists because we have rules about confidentiality which prevent us from discussing your personal issues in public.

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I have accounts with social media sites such as Facebook, LinkedIn and Google+, which are used for business purposes. I am happy to connect at any level with those with a general interest in hypnotherapy.

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I will not accept friend requests from therapy clients on any social networking sites. My reason for this is that I believe that adding clients as friends can compromise your confidentiality, and blur the boundaries of our therapeutic relationship. If you have questions about this, please feel free to bring it up in-session; I'm happy to talk more about it.

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You are welcome to like my Facebook business page, to follow any of my other social media business pages, and to read and share the articles and comments there. You may leave general comments and questions but remember that anything you post is visible to everyone who visits the page.

 

If you want to ask anything specific to you please email* or phone me. If I feel any posts you have made blur the line of our professional relationship or identify you as a client, I will delete them.

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It is not a regular part of my practice to search for clients online, via search engines or social media. The exception to this would be if one of the Duty of Care provisions applied.

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*Please note that email is not completely secure or confidential. Records of any emails you send me are automatically kept in the logs of your own computer and mine. Although in practice it seems unlikely, in theory they could be read by the system administrator. With this in mind it's best not to use email to send any information that should be kept private. Any emails you send me that refer to your therapy will be printed and kept in your confidential records.

 

Testimonials

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I do not use testimonials for my therapy work since I believe that they are not a reliable guideline for clients who may be considering using my services. This is why:

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  • Without specific identification (i.e. if they appear as 'Ms A of B says...') they are pointless and could have been written by anyone. With identification (i.e. if they include a name and address) they breach a client's confidentiality.

  • Therapists see a lot of clients, and are unlikely to publish negative feedback. There is nothing to say that what is published is representative of their results.

  • Every person is different and so is every course of therapy; another person's experience may not be the same as yours.

 

Please treat your own right to privacy and confidentiality with the same respect I do, and also bear in mind that I may not be aware of any posts you make on social media sites. If we are working together, I hope that you will bring your feelings and reactions to our work directly into the therapy room. This can be an important part of therapy, even if we decide we are not a good fit.

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If you do choose to write something on a site, I hope you will keep in mind that you may be sharing personally revealing information in a public forum. I urge you to create a pseudonym that is not linked to your regular email address or friend networks for your own privacy and protection.

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None of this is meant to keep you from sharing that you are in therapy with me wherever and with whomever you like. Confidentiality means that I cannot tell people that you are my client, but you are more than welcome to tell anyone you wish that I'm your therapist, or how you feel about the treatment I provided to you. I welcome recommendations ('word of mouth' referrals) if you think I can help someone you know.

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If you feel I have done something harmful or unethical, I ask that in the first place you contact me about your concerns.

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Social media policy by http://www.debbiewaller.com  adapted from an original by http://www.drkkolmes.com

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