Ouro client privacy notice
I, Alysa Rixon, trading as Ouro Counselling and Coaching, am the data controller responsible for your personal information. This privacy notice tells you what to expect me to do with your personal information.
Introduction
In order for me to fulfil my responsibilities as a counsellor or coach I will need to gather, record and use personal information (data) about you, to enable me to provide you with a professional service.
The UK General Data Protection Regulation, the Data Protection Act 2018 and related data-protection legislation requires me to be clear about what happens to this information, how it is kept, including where it is filed, how long I keep it and what your rights are. Your Working Agreement covers some of this information, but this Data Privacy Notice sets it out more clearly.
Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. This will include information such as your name and contact information (including email address and phone number) when you enquire about my services, as well as relevant medical and any previous counselling history that you tell me about, or other personal information that will help me provide counselling or coaching services to you. This will include information that you give me over the phone, face to face, by letter or by email.
The information I may collect
Depending on your relationship with me, I may collect:
• your name and contact details
• information contained in an initial enquiry or referral
• appointment, attendance and communication records
• emergency-contact information, where agreed
• information relevant to counselling or coaching, including brief session notes
• payment, invoice and transaction information
• information relating to complaints, safeguarding concerns or legal matters
• limited technical information generated when you use my website.
How and why I process your personal data
I comply with my obligations by keeping your personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
Where appropriate, I rely on legitimate interests as my lawful basis for collecting and using your personal information.
My legitimate interests are to operate a safe, ethical and effective counselling and coaching practice; to respond to enquiries; assess whether I can offer an appropriate service; communicate with prospective and current clients; arrange and manage appointments; maintain appropriate professional records; protect the wellbeing and safety of clients and others; manage complaints or legal claims; and meet the standards expected by my professional body, supervisor and insurer.
I only collect and use information that I reasonably need for these purposes. I have considered the possible impact on your privacy and concluded that this use is necessary and proportionate, is within the reasonable expectations of someone seeking counselling or coaching, and does not override your rights and freedoms.
Counselling records and special category information
The information you share during counselling is likely to include special category personal data. For example, this may include information about your physical or mental health, racial or ethnic origin, religious or philosophical beliefs, sexual orientation or sex life.
I process limited special category information where this is necessary to provide counselling, maintain continuity and safety in our work, and meet my professional responsibilities. My Article 6 lawful basis is legitimate interests under Article 6(1)(f). My applicable Article 9 condition for providing counselling is Article 9(2)(a), your explicit consent. You may withdraw your consent at any time, but please be aware that this will likely mean that I cannot provide counselling or coaching services to you, or, if you were to withdraw that consent after your counselling or coaching has started, I would not be able to continue to offer that service to you.
I may also retain and use relevant special category information where this is necessary for the establishment, exercise or defence of legal claims under Article 9(2)(f). This may include responding to a complaint, professional-conduct process, insurance matter or legal claim, or explaining and evidencing a safeguarding or confidentiality decision.
I keep counselling notes brief, relevant and limited to what I reasonably need. They are stored securely, access is restricted and they are not used for unrelated purposes.
I store your contact details separately from counselling session notes wherever reasonably practicable. Session notes use a client reference rather than your full name, although I recognise that the content may still constitute identifiable personal information and protect it accordingly.
I retain counselling records for six years after our work ends, unless there is a clear reason to keep particular information for longer, such as an ongoing complaint, safeguarding matter, insurance issue or legal claim. At the end of the relevant retention period, the records are securely destroyed.
You may ask me to erase your information. However, the right to erasure is not absolute. I may need to retain some or all of your counselling records where continued processing is necessary for the establishment, exercise or defence of legal claims or where another legal obligation or applicable exemption requires or permits me to do so.
Sharing your personal data
I will treat your personal data as confidential.
I discuss my work in regular clinical supervision. I minimise identifying information, for example I would not use your full name or direct contact details.
In exceptional circumstances I may disclose relevant information where required by law or where I reasonably believe disclosure is necessary to protect you or another person from serious harm. I may also disclose information in connection with safeguarding concerns, terrorism, money laundering or other circumstances where a specific legal obligation applies. I may share limited information with HM Revenue and Customs, courts, regulators, safeguarding authorities, emergency services or law-enforcement bodies where disclosure is required or permitted by law and is necessary and proportionate.
I will discuss any proposed disclosure with you unless I believe that to do so could increase the level of risk to you or someone else.
I may use carefully selected providers to support the administration of my practice. These may include my website and contact-form provider, email and telephone providers, video-conferencing provider, payment processor, bank, secure record-storage provider, accountant, IT support provider, insurer and legal advisers.
These providers receive only the information reasonably necessary for their role. Where they process information on my behalf, I require appropriate contractual and security safeguards.
I aim to use service providers that store and process client information within the UK or another jurisdiction recognised as providing adequate protection. I do not knowingly transfer counselling notes outside the UK.
Where I get personal information from
Most personal information is provided directly by you when you contact me, complete a form, arrange an appointment or take part in counselling or coaching.
I may also receive limited information from a counselling directory or another referrer where you have contacted me through that service or authorised the referral.
When you use my website, limited technical information may be collected through essential cookies and, where enabled, analytics tools. Further information is provided in my website cookie notice.
I do not purchase personal information about prospective or current clients from data brokers.
How long I keep information
I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for I look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
In some circumstances I may anonymise your personal data for research, professional reporting, or statistical purposes in which case I may use this information indefinitely without further notice to you.
Your rights and your personal data
Unless subject to an exemption under the law, you have the following rights with respect to your personal data: -
The right to request a copy of your personal data which I hold about you;
The right to request that I correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary for me to retain such data;
Where I have relied on your consent for the processing of your data, you have the right to withdraw your consent to the processing at any time;
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data (in relation to marketing);
The right to lodge a complaint with the Information Commissioner’s Office. You can contact the Information Commissioner’s Office on 0303 123 1113 or via email (see the “Contact Us” page on their website: www.ico.org.uk) or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Further Processing
If I wish to use your personal data for a new purpose not covered by this Privacy Notice, then I will provide you with a new Privacy Notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, I will seek your prior consent to the new processing.
How I will communicate with you
To provide counselling or coaching to you, I will need to contact you either by telephone, text, WhatsApp and/or by email (depending on your preferences). Such communication methods will only be used to arrange, change or confirm appointments and to send information to you. For security reasons I will not engage in any ongoing communication with you outside of the counselling room.
Contact Details
To exercise all relevant rights, ask any questions, or send me a complaint please in the first instance contact me at the telephone number or email address provided above.