Privacy policy, data protection statements, ai policy, and complaints procedure
PRIVACY POLICY & DATA PROTECTION
Introduction
Please note: ‘therapy’ also refers to ‘coaching’ and ‘mediation’.
Your privacy is very important to me and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to me. I adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003. This privacy notice tells you what I will do with your personal information from initial point of contact through to after your therapy has ended, including:
• Why I am able to process your information and what purpose I am processing it for
• Whether you have to provide it to me
• How long I store it for
• Whether there are other recipients of your personal information
• Whether I intend to transfer it to another country,
• Whether I do automated decision-making or profiling, and
• Your data protection rights.
I am happy to chat through any questions you might have about my data protection policy and you can contact me via mona@monascottnorman.com
‘Data controller’ is the term used to describe the person/organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is me.
I am registered with the Information Commissioner’s Office, registration number ZC141478.
My contact details are - mona@monascottnorman.com
Privacy notice
My lawful basis for holding and using your personal information.
The GDPR states that I must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which I am processing your data. I have explained these below.
If you have had therapy with me and it has now ended, I will use legitimate interest as my lawful basis for holding and using your personal information.
If you are currently having therapy or if you are in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of our contract.
The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately.
This type of information is called ‘special category personal information’. The lawful basis for me processing any special categories of personal information is that it is for provision of health treatment (in this case counselling) and necessary for a contract with a health professional (in this case, a contract between me and you).
How I use your information
Initial contact
When you contact me with an enquiry about my services I may collect information to help me satisfy your enquiry. This could include: Your full name, Date of Birth, home address and GP contact details.
Alternatively, your GP or other health professional may send me your details when making a referral or a parent or trusted individual may give me your details when making an enquiry on your behalf.
If you decide not to proceed I will ensure all your personal data is deleted within one week. If you would like me to delete this information sooner, just let me know.
While you are accessing therapy, be assured that everything you discuss with me is confidential.
All information shared by you with me, would be held in strict confidence. The exceptions to this rule are 1. To prevent harm to self or other (including serious crimes, balance of public interests: murder, manslaughter, rape, treason, kidnapping, child abuse); acts of terrorism; drug trafficking and money laundering; road traffic offenses; child protection; Female Genital Mutilation; court order; tribunals; family court and civil court; criminal court; mental capacity 2. Where there is a need to discuss anonymised client material with a supervisor.
Additionally, information sent electronically cannot be guaranteed to be secure. You can talk to whoever you choose about your therapy. I would not accept or give friends invitations for social media sites.
I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely on an encrypted device and locked in an irremovable cabinet and are not shared with any third party.
I will keep anonymised written notes of each session, these are kept on an encrypted device separate from your personal details.
For security reasons I do not retain messages for more than six years. If there is relevant information contained in a message I will copy this into a word documents and store this anonymously on an encrypted device. If necessary I will store these on an encrypted device, locked in an irremovable cabinet, solely accessible by myself.
After therapy has ended
Once therapy has ended your records will be kept for six years from the end of our contact with each other and are then securely destroyed. If you want me to delete your information sooner than this, please tell me.
Third party recipients of personal data
I sometimes share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks. In such cases I have carefully selected which partners I work with. I take great care to ensure that I have a contract with the third party that states what they are allowed to do with the data I share with them. I ensure that they do not use your information in any way other than the task for which they have been contracted.
Your rights
I try to be as open as I can be in terms of giving people access to their personal information. You have a right to ask me to delete your personal information, to limit how I use your personal information, or to stop processing your personal information.
You also have a right to ask for a copy of any information that I hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at ico.org.uk/your-data-matters.
If I do hold information about you I will:
• give you a description of it and where it came from;
• tell you why I am holding it, tell you how long I will store your data and how I made this decision;
• tell you who it could be disclosed to;
• let you have a copy of the information in an intelligible form.
You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you. To make a request for any personal information I may hold about you, please put the request in writing addressing it to mona@monascottnorman.com.
If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by writing or emailing to the contact details given above. I would welcome any suggestions for improving my data protection procedures.
If you want to make a formal complaint about the way I have processed your personal information you can contact the ICO which is the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint.
Data security
I take the security of the data I hold about you very seriously and as such I take every effort to make sure it is kept secure by storing anonymised data on encrypted devices and in a locked cabinet.
Visitors to my website
When someone visits my website, I do not use a third party service, to collect standard internet log information and details of visitor behaviour patterns.
I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.
Third party links
This website may include links to third party websites, plug ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third party websites and are not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy policy of every website you visit.
Cookies
Like most websites we use cookies to help the site work more efficiently.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.
If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.
The data I collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
I may collect, use, store and transfer different kinds of personal data about you, grouped together as follows:
· Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, job status/description, and gender.
· Contact Data includes billing address, delivery address, email address and telephone number.
· Financial Data includes bank account and payment card details.
· Transaction Data includes details about payments to and from you and other details of products and services you have purchased.
· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug - in types and versions, operating system and platform, and other technology on the devices you use to access this website.
· Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
· Usage Data includes information about how you use our website, products and services.
· Marketing and Communications Data includes your preferences in receiving marketing from me and our third parties and your communication preferences.
Change of purpose
I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason, and that reason is compatible with the original purpose.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact me.
If I need to use your personal data for an unrelated purpose, I will notify you and explain the legal basis which allows us to do so.
Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Personal data may be shared with a third party for the purpose of any disputes/complaints.
Data Retention
How long will you use my personal data for?
I will only retain your personal data for as long as reasonably necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. I may retain your personal data for a longer period in the event of a complaint or if I reasonably believe there is a prospect of litigation in respect to my relationship with you.
To determine the appropriate retention period for personal data, I consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law I have to keep basic information about my clients (including Contact, Identity, Financial and Transaction Data) for six years after termination of contact. In some circumstances you can ask me to delete your data: see ‘your legal rights’ below for further information.
I will always anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case I may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the following terms:
· Request access to your personal data
· Request correction of your personal data
· Request erasure of your personal data
· Object to processing of your personal data
· Request restriction of processing your personal data
· Request transfer of your personal data
· Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact me. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I could refuse to comply with your request in these circumstances.
What I may need from you
I may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
I try to respond to all legitimate requests within one month. Occasionally it could take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.
AI policy
Artificial Intelligence (AI) tools are being explored for their usefulness in therapy. I hereby define my stance on the use of AI as part of, or alongside, therapeutic process. The aim is to support ethical and legally compliant practice.
As a therapist coach and mediator, I acknowledge the increasing use of AI. Clients might use AI to support their journal writing and reflections. However, AI is not a replacement for professional therapy, coaching or mediation due to its inability to hear nuance, provide empathy, assess risk, provide trauma-informed care, apply human judgement, or work in the best interests of the AI user.
I do not use AI to deliver therapy.
I do not use AI to process sensitive personal information.
I do not use AI for record keeping.
I do not use AI to assist me in making assessments or decision-making.
I do not use AI for supervision purposes.
I do not use AI for scheduling, administration or invoicing.
The policy will be reviewed at least annually.
COMPLAINTS PROCEDURE
In the event you have a complaint about my services or conduct in relation to therapy or coaching, in the first instance, please contact me at mona@monascottnorman.com to attempt to resolve the complaint directly. Should the issue remain unresolved please contact the British Psychological Society at conduct@bps.org.uk or complaints@bps.org.uk or write to them at BPS Quality Assurance and Standards Officer, St Andrews House, 48 Princess Road East, Leicester LE1 7DR.
If you have a complaint about my services as a family mediator please contact me at mona@monascottnorman.com to attempt to resolve the complaint directly. Should the issue remain unresolved please contact the Family Mediation Council at complaints@familymediationcouncil.org.uk.