This policy applies to information I collect about:
- People who contact me, including people who fill out forms on the website and/or subscribe to my newsletter;
- People who use my psychotherapy, counselling, supervision, training, consultancy, or any other services (Clients).
The purposes of processing
Personal data is collected in order for me to provide my services to my clients (i.e. psychotherapy, counselling, supervision), as well as for the following purposes: contacting people based on their enquiries, sending out a periodic newsletter, spam protection, analytics, managing contacts and sending messages.
People who contact me
Contacting me may include emailing me, texting me, calling me, filling out the contact form, or filling out any other form on my website. By filling in the contact form or sending me an email with your personal data, you authorise this website and me to use these details for the purpose of replying to requests for information, quotes or any other kind of request as indicated in the email or by filling out the contact form.
Any email sent to me, including any attachments, may be monitored and used by me for reasons of security. Email monitoring or blocking software may also be used.
Clients are considered all individuals that are users of my psychotherapy, counselling, supervision, training, consultancy or any other services unless specifically stated otherwise. Psychotherapy and counselling may also be referred to under a common term of ‘therapy’.
Personal information that I obtain
Personal information means any information about an individual from which that personal can be identified. I may obtain, use, store and transfer different kinds of personal information about you.
- Identity and contact information includes your name, marital status, title, date of birth, gender, address, email address, telephone numbers, next of kin etc.
- Professional information includes qualification, registration with relevant regulatory bodies, details of other supervisors / tutors, indemnity insurance certificate, DBS checks, professional membership, ICO registration certificate and your professional on-line profile / website.
- Therapy and/or supervision information includes information provided to me or generated by me for the purposes of your therapy or supervision.
I may also obtain special category data about you. Special category data includes personal data which reveals racial or ethnic origin, religious or philosophical beliefs, trade union membership, data concerning health and data concerning a person’s sex life or sexual orientation.
How I use your personal information
I use your personal information for the following purposes:
- For the purposes of conducting my services.
- For the purpose of accounting, bookkeeping and invoicing. I may be using professional accounting cloud-based systems for accounting, bookkeeping, invoicing etc. I will use minimum possible information when using such systems (i.e. your name or initials, email, address, etc.). Please note that I may be using a professional contractual accountant that may have access to this system, but also acts in line with strict privacy guidelines.
- For the purpose of meeting my professional, regulatory and legal obligations, including with respect to professional supervision.
- For the purposes of regulatory or legal proceedings.
- Where I believe you or others are at risk of harm, for the purposes of safeguarding you or others against such harm.
The basis upon which I use personal information
I will only use and hold your personal information (including special category information) where there is a lawful basis for me to do so. The relevant lawful bases are:
- Where it is necessary for my legitimate interests as a professional in providing therapy, supervision, or training to you and meeting my own professional obligations to be supervised with respect to my role as your therapist, supervisor, or trainer, which do not override your interests and fundamental rights.
- Where it is necessary to comply with a legal obligation.
When I use and hold your special category information, it will be where it is necessary:
- For the purposes of conducting services and in light of my professional obligations of confidentiality.
- For the purposes of safeguarding an individual from harm.
- To establish, exercise or defend legal claims.
I may not rely upon your consent in using or holding your personal information or special category information in the usual course of conducting my services.
How long I keep personal information
Personal information shall be processed and stored for as long as required by the purpose they have been collected for.
Generally, I will hold your personal information gathered for the purpose of providing therapy services for a period of seven years after the conclusion of the service, unless it is necessary to retain your personal information for longer, for example, because:
- There is an ongoing possibility of regulatory or legal proceedings.
- I am subject to an ongoing legal obligation.
Who I share personal information with
When providing therapy, supervision, or training services, I will only share your personal information, where it is necessary for the purposes of conducting my services, with the following:
- My supervisor for the purposes of my own professional obligations to be supervised with respect to my professional role.
- The relevant professional regulator where it is necessary to report potential breaches of ethical principles or codes of professional conduct.
- Relevant bodies or organisations where I may be legally obliged to do so.
International transfer of personal information
I do not transfer your personal information outside of the European Economic Area.
How I protect personal information
I have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
Data is kept on a laptop computer which is security protected with a password and in a professional cloud-based service that is also password-protected.
I will only share your personal information where it is necessary for the purposes above and I am satisfied that the individual or organisation complies with its obligations to keep your personal information secure.
My supervisors are subject to professional obligations of confidentiality. The information I may share in supervision will be shared in the manner that will attempt to retain your anonymity.
The data is processed at my operating offices and in any other places where the parties involved in the processing are located.
Depending on my location, data transfers may involve transferring the data to a country other than UK. Data transfer in terms of location will also depend on your location at the time.
You are also entitled to learn about the legal basis of data transfers to a country outside the European Union and about the security measures taken by me to safeguard your data.
I may use cloud service provider(s) to store data with, whereby I shall exercise care in using cloud service provider(s) with data protection policies in compliance with the EU principle and GDPR.
Personal data shall be processed and stored for as long as required by the purpose they have been collected for.
Personal data collected for purposes related to the performance of a contract between myself and a Client shall be retained until such contract has been fully performed.
I may be allowed to retain personal data for a longer period whenever have given consent to such processing, as long as such consent is not withdrawn. Furthermore, I may be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, personal data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
You have the following rights:
- Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your personal data.
- Request access to your personal information (commonly known as a “data subject access request”). You can request a copy of your personal information that I hold and check that I am lawfully processing it.
- Request correction of the personal information that I hold about you. This enables you to request for any incomplete or inaccurate data I hold about you corrected.
- Request erasure of your personal information. You can ask me to delete or remove personal information where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law.
- Object to processing of personal information where I am relying on my legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
- Request restriction of processing of your personal information. You can ask me to suspend the processing of your personal information in the following scenarios: (a) if you want me to establish the information’s accuracy; (b) where my use of the data is unlawful but you do not want me to erase it; (c) where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to my use of your information but I need to verify whether I have overriding legitimate interest to use it.
These rights are subject to various legal exceptions. If you make any of the requests above, I would explain to you in my response if I have relied upon any of these exceptions.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). Full details can be found on the ICO’s website www.ico.org.uk. However, if you have any concerns, I would be grateful for a chance to deal with these before you approach the ICO.
If you have any questions or concerns about my use of your personal information, please contact me here: zivkovicales1 [at] gmail.com
Changes to this privacy notice
I keep this privacy notice under regular review also with the aim to reflect changes in law and practice.
Date: June 2019