PRIVACY POLICY
This privacy notice has been written in a way that I hope is clear and easy to understand. However, in order to keep it concise I might refer to terms or situations which are not immediately obvious to you. If you come across anything that you would like to have explained, please do contact me by emailing swoolsey@btinternet.com and I will do our best to provide further clarification. As a counsellor I highly value your right to privacy. As such I will only use the personal data that you entrust us with for the purpose which it was given to me. I adhere to the current UK data protection legislation, including the Data Protection Act 2018, General Data Protection Regulation (EU/2016/679 - GDPR) and Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR).
Sandra Woolsey is registered with the information Commissioners Office (ICO) under the security number: CSN0983643 This privacy notice covers the following points: What personal data I collect The purposes of processing your personal data The legal basis for processing your personal data How I store your personal data Who I share your personal data with and why How long your personal data is retained Your rights around the use of your personal data How to contact the authority if you have concerns What personal data do I collect? The details collected at the time of your initial contact with me will be used throughout the counselling relationship to communicate with you in relation to appointments. As a reminder, these details include: Your name The name and age of a child or young person you are applying on behalf of Your preferred contact information, i.e. your email address or a telephone number
The reason that you are seeking counselling Page 1 of 5 Privacy Notice – Sandra Woolsey Last revision date: 30/08/2025 Next review date: 30/08/2026. When you begin your counselling journey with me, I will collect additional personal data as part of my registration process and to ensure that the arrangement and work together can be carried out. This information includes: Details relating to your general physical health, e.g. level of fitness, amount of alcohol you consume on a weekly basis Details relating to any medically diagnosed conditions relevant to the counselling work Details relating to your current emotional state Details regarding your sexual orientation, preferred gender pronoun * Details regarding your nationality * Age(s) of and relationship of significant others, e.g. parents, siblings, children, partner * Please note, some of the above personal data (marked with an asterisk (*)) is collected on an optional basis, as it is not essential to carry out the counselling work but can be helpful within it.
You will also be required to sign a Working Agreement (contract) for the type of counselling appointment you undertake, which will also contain Your signature Your address The name, address and contact telephone number of your GP surgery The name, contact telephone number or email and relationship to you of an emergency contact Once the counselling work has begun, a record of your sessions will also be kept, in addition to the above mentioned personal data. This means that I will take brief notes during your sessions, to help the counselling agreement run smoothly and serve to aid memory about the work, as is standard professional practice. These notes are available to you to view at any time upon request and are anonymised as much as practically possible to protect your privacy.
The purposes of processing your personal data As might reasonably be expected, the Data Protection Act 2018 and GDPR both state that personal data can only be collected and used if there is a legal reason for doing so. The below table will hopefully help show you which legal condition I am relying upon when using your personal data. What data What it is used for Legal condition Legitimate Interests Name and/or contact details Communications - e.g. booking appointments, facilitating video call counselling sessions etc. Performance of contract N/A Issuing invoices for payment Performance of contract Page 2 of 5 Privacy Notice – Sandra Woolsey N/A Last revision date: 30/08/2023 Next review date: 30/08/2024. Last revision date: 30/08/2025 Next review date: 30/08/2026.
Execution of counsellor’s professional will Explicit consent N/A Emergency contact name and/or contact details Communication, should an emergency with you arise during a counselling appointment Legitimate Interest To aid in meeting our safeguarding requirements. Health information, e.g. details relating to current emotional state Session notes Performance of contract N/A Details relating to sexual orientation and nationality Provision of counselling service Legitimate Interest To aid in the counselling work, so the performance of the contract. Details of significant others Provision of counselling service Legitimate Interest To aid in the counselling work, so the performance of the contract. Name and/or contact details of other therapists Referrals Explicit Consent N/A.
How I store your personal data depends on the type of record that I hold the personal data on. Paper records, such as signed working agreements or session notes will be stored in a secured filing cabinet, contained in areas with access restrictions. I store electronic records, such as your contact details, in a number of different systems. As far as is reasonably practical, these systems have been carefully selected on grounds of the security they enforce. All systems are set up with unique username and strong password combinations and utilise access controls to restrict unauthorised access. How long I retain your personal data The length of time your personal data will be retained for depends very much on the type or personal data it is and the reason that it is collected and used. Following your initial contact with me, should you proceed with the counselling work, your personal data will be held for the lengths of time outlined below: What data Retention period Personal data relating to working agreement, including name, contact information, emergency Until the end of the counselling relationship. contact information, GP surgery contact information, health data.
Personal data relating to working agreement, including name, contact information, health data. For up to 7 years to meet the requirements stipulated by my counselling insurance company, with the details of children and/or young people being held for 7 years after they turn 18. All personal data relating to financial records, including name, contact information. Until the end of the 5th financial year after the end of the counselling relationship as required by Her Majesty's Revenue and Customs (HMRC). Your rights relating to your personal data Your personal data belongs to you. As a client of mine you entrust your personal data to me, so that I can provide you with the therapeutic help that you are seeking, but you retain certain rights over your data and how it is used. Below are a list of your rights and how you can exercise them. The right to be informed In a nutshell, it is your right to know how and why your data is being collected and used by me. I hope that this Privacy Notice provides you with that information. Should anything be unclear though, please do not hesitate to contact me. The right of access You have a right to know what data I hold on you. As the controller of your data, I am required to respond to any request that you make to see the data we hold within 30 days of you making such a request. This is commonly referred to as a Data Subject Access Request. If you would like to see the data I hold on you, please discuss this with me.
Please note, while it may sound contradictory, to properly protect your privacy, I may be required to request additional personal data to verify your identity before providing the personal data to you if you email me with a data subject access request. This is in an effort to stop other people claiming to be you from getting access to your personal data. The right to rectification You have the right to ensure that any personal data that you have provided me with is correct. As such, if your circumstances change, for example you get a new contact telephone number, or wish to change your preferred method of contact from telephone to email, please do provide me with the up-to-date information and we will correct my records immediately. Please note, there may be circumstances when I am not required to follow up on you exercising your right for rectification. Full details about this right can be found here: www.ico.org.uk/your-data-matters/your-right-to-get-your-data-corrected Page 4 of 5 Privacy Notice – Sandra Woolsey Last revision date: 30/08/2023 Next review date: 30/08/2024
The right to erasure This right allows you to ask me to delete the personal data we hold on you. However, there are certain instances when I would not be able to honour your request, including those were I am under legal obligations to retain the data, for instance the HMRC requirement for my financial records to be held for 5 financial years. Also, please note, while you are actively engaged with the counselling work, I would not be able to delete the personal data that I hold on you, as this is required by us to fulfil my side of the working agreement. The right to restrict processing Related to your right to erasure, you have a right to restricting how we use the personal data that you have provided me with. This right is closely linked to your right to erasure, and also has some restrictions as to when it can be exercised. If you would like more information about this right, you can find some here: https://ico.org.uk/your-data-matters/your-right-to-limit-how-organisations-use-your-data The right to data portability Should you wish to move from using me to another therapist outside the organisation, you have the right to request that I make the personal data we hold on you available in a format that easily accessible. Specifically, this right applies to data we hold electronically. Should you wish to exercise this right, please do contact me via email at swoolsey@btinternet.com.
The right to object Another right that is similar to both the ‘right to erasure’ and the ‘right to restrict processing’ is your right to ask me to stop using your data at any time. This again does only apply in certain circumstances, so please do contact me to discuss this exercising right. Also, you can find additional information here: https://ico.org.uk/your-data-matters/the-right-to-object-to-the-use-of-your-data Rights in relation to automated decision making and profiling I do not profile you or make any automated decisions regarding you in any way. As such, while this is a right you have, it does not apply to the services I provide. How to contact the authority if you have concerns
If you have any concerns around the use of your personal data, I would prefer it is you would address these with me first. My email address is swoolsey@btinternet.com. However, if you do not feel that I am providing you with a satisfactory response, you are also entitled to lodge a complaint with the Information Commissioner’s Office (ICO), which is the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals. You can contact the ICO via their website: https://ico.org.uk