Westwood Counselling – GDPR Privacy Policy (Clinical)

This policy details Westwood Counselling`s (W C) compliance with the terms of the General Data Protection Regulation (GDPR) regarding the responsible and secure use of client data. W C already adheres to the Nursing & Midwifery Council (NMC) code of conduct in relation to the handling, management and storage of client data. In addition, W C has its own GDPR privacy policy, its purpose being to let clients, referrers and onward contacts, and supervisees, know what personal information it collects and holds, why this data is collected, how long it is kept and what client rights are with regards to this personal data.

  1. Referrals – From Client Employer
    1. When a client is referred for psychological assessment and/or treatment with W C, a referral form/letter/email will accompany the referral direct from the clients employer, which normally contains information concerning client name and address, date of birth, and contact telephone number(s). Also, in some cases, that consent has been given for W C to contact the client direct by phone to arrange a convenient face-to-face/virtual clinical contact. If the client has not seen/used the W C company website, he/she will be provided with details of its existence/access.
    2. Prior to the first face-to-face/virtual meeting (clinical referrals only) a casefile will have been made containing the referral form/letter/email, and any personal data already given, will be checked at the first meeting.
  2. Referrals – From Solicitors/Personal Injury Companies Etc.
    1. When a client is referred for psychological assessment and/or treatment with W C, as a result of a personal injury claim, a referral form/letter/report/email will accompany the referral, which normally contains client information such as name and address, date of birth, and telephone number(s), together with details (some of which may be sensitive) of the accident/incident that caused/led to the injury to the client. Also, that consent has been given for W C to contact the client direct by phone to arrange a convenient face-to-face/virtual clinical contact.
    2. Prior to the first face-to-face/virtual meeting a casefile will have been made containing the referral form/letter/report/email, and any personal data already given will be checked at the first meeting.
  3. Self Referrals
    1. When a client makes direct contact as a `self referral`, normally via a phone call or email, basic personal data will be taken in the first instance, such as name, address, date of birth, telephone number, a precis of the issue(s) that require addressing, how the client became aware of W C (Counselling Directory website, word of mouth, Westwood Counselling website etc.) If the client has not seen/used the Westwood Counselling website he/she will provided with details of its existence/accessibility.
    2. When a client makes contact via the Counselling Directory website (to which W C subscribes) he/she will give a brief overview of the reason for requiring clinical support, together with their name and contact details. This will come to W C via email direct from Counselling Directory website. Contact will be made by W C to establish if `potential` client wishes to make an appointment and have a brief discussion of the issue(s) etc. If the client has not seen/used the Westwood Counselling website he/she will provided with details of its existence/accessibility.
    3. At the first face-to-face/virtual meeting a casefile will be created from information gathered such as name, date of birth, address, contact telephone number(s), state of health and previous health (including mental health) history, GP details, family details, brief overview of the client needs (issues/concerns etc.) in relation to therapy, in order that the appropriate therapeutic model is used, and if `forms/questionnaires` are required to be completed. All the data, which will/may include personal sensitive data, collected at the first, and future meetings, will be held as part of the casefile.
  4. EMDR Supervision – Self or Organisation Referral
    1. In relation to clients who require access for EMDR supervision, whether self (private) or organisation referred, the only information collected at the first and subsequent sessions (including any telephone/virtual supervision) will be name, address, telephone contact, employment/employer name plus notes of cases the client has brought to discuss and advice given (for future reference only). In addition details of the person`s level of, and experience with, using EMDR will be made.
  5. Clients will be asked to sign a specific communication consent detailing those that are authorised for W C to communicate with:-
    • To provide clients with psychological services requested from W C.
    • To fulfil any administrative, legal, ethical and contractual obligations.
  6. W C will not share any information about clients with other organisations or people, except in the following situations:
    • Consent – Information may be shared with relevant medical professionals and/or others who the client has requested and/or WC has been authorised to contact.
    • Serious harm – Information may be shared with the relevant authorities if there is reason to believe that this may prevent serious harm being caused to the client or another person.
    • Compliance with law – Information may be shared when the law requires it - i.e. safeguarding, terrorism, drug trafficking and serious crime.
    • Supervision – It is an ethical requirement for any clinician offering psychological services to have regular supervision. Any supervisor used is an accredited member of the relevant accrediting body and works within their ethical framework.
  7. How does W C keep client information safe?
    • All information that clients provide to W C is stored as securely as possible. All reasonable precautions will be taken to prevent the loss, misuse or alteration of information given.
    • All paper forms and correspondence are kept in locked storage.
    • All electronic files are kept on password-protected devices with appropriate virus protection software.
    • All reports/letters/information are sent securely via email or posted direct to recipient.
    • In the case of virtual counselling (Skype/Zoom/WhatsApp Video etc.) all appropriate safeguards are taken to ensure systems used are safe and secure.
    • Whilst W C endeavours to keep systems and communications protected against viruses and other harmful effects, it cannot bear responsibility for all communications being virus free.
    • Client notes and other documentation are destroyed seven years after `discharge`.
    • Any known data breaches will be reported to the ICO within 72 hours.
    • Any requests for personal data will need a written form of signed authority. Data will be supplied within one month and sent via email or postal delivery.
    • No personal/identifiable data is stored on the W C website www.westwood counselling.co.uk and the ‘contact us form’ comes direct to a secure personal email account. Clients are then contacted via telephone and/or using email address robles1@hotmail.co.uk.
  8. Clients have the right under GDPR to:
    • Access their personal data - rectify, erase or restrict their data, object to the processing of their data - request transfer of data (data portability), withdraw consent for WC to hold and process their data at any time. However, if this did happen while actively receiving psychological assessment/treatment, then assessment/treatment would have to end. Consent to withdraw can be done by stating this in an email to robles1@hotmail.co.uk.

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