LEWES LOW COST COUNSELLING SERVICE
GDPR DATA PROTECTION POLICY
The service
The service is based in Lewes and considers eligible people from a twenty mile radius from the centre of Lewes and also on a case by case basis. We are a Registered Charity No. 1168967. We have a team of counsellors, five of whom are Trustees. We work in accordance with the ethical framework of professional counselling bodies.
Client sessions
Our clients may be with us for short, medium or long-term work depending upon their needs. When a client begins work with a counsellor, a contract is made, and an information form is completed with the name, address and telephone number of the client and the name of the General Practitioner is asked for. This information is used to enable contact with the client. The client is told that the GP will not be contacted without the client’s permission, except in the case that there is a high risk to the client or others. This personal data is therefore held lawfully under contract.
Allocation
Clients come to our service either by Hushmail, telephone or via our website. There is a service phone number and this phone is answered by one person who is allotted this task. Clients are then allocated to particular counsellors depending upon free spaces. There is one person in the group who deals with the allocation, who then keeps a list of people either waiting for allocation or who have recently been allocated. This information is kept in a folder in a locked cabinet. However, the situation may arise where the potential client decides they do not wish to use our service, then their details are erased. This data is held for legitimate purposes.
Client Records
During the course of the work with you, the counsellor needs to make brief notes about your situation, which the counsellor will keep during the length of the counselling. This information is kept by the counsellor in locked cabinets, for a number of years defined by their insurers, after counselling has ended. You have the right to read your record made by the counsellor and to request any mistakes be rectified. These notes will be supplied on request within a month without charge. You also have the right to request erasure of data if the service no longer need the data because the storage period has been completed. All requests will be considered on a case by case basis. Counselling notes are kept in a manual form in a coded file and the identifying information is kept in a separate locked filing cabinet.
Supervision
We are required to attend supervision for professional purposes but the supervisor does not have identifying information about you. They will have knowledge of the issues which you bring to counselling.
The legal grounds for holding your data are that processing is essential for the performance of our contract.
In some exceptionally rare circumstances, your contact details may need to be shared with other agencies, e.g. in the case of terrorism, drug, money laundering, child protection or following a court order for disclosure. In the case of immediate risk of substantial harm to yourself or others the counsellor may override the duty of confidentiality but when risk is less immediate there will be a discussion with you first to explore the risks.
In the event that your counsellor is incapacitated and unable to continue with counselling, your contact details will be accessed by a Trustee so that they can explain the situation.
Telephone or online counselling
The service is currently offering sessions to clients using either telephone or online platforms due to the ongoing pandemic. To comply with data protection counsellors will ensure that they are using a safe and confidential space to work from where no-one will overhear their voice or their client’s voice or they or the client can be seen during sessions. They will ensure that they use all the necessary equipment and that the equipment is secure. The counsellor will require their client to ensure that the space they talk to the counsellor in is safe, confidential, ensuring they are not overheard or seen and the equipment used is appropriate and secure. No technology is absolutely secure but we take this issue seriously.
ICO Registration
As a charity we are registered with the ICO reference number ZA495090