Greenwich Counselling Services privacy notice

Information we collect about you

We collect information about you when you refer yourself to our services.
We also collect information when you attend assessments appointments, therapy sessions, groups, complete referral forms, measures and monitoring forms, voluntarily complete client’s surveys and provide feedback.

This data can be collected in many ways, either verbally during an appointment, on the telephone, or written via paper forms, online forms, text or email. We will use the most secure methods that are available to us to collect your data, considering your access needs.

We process the following personal data belonging to clients:

  • Names and preferred pronouns; date of birth; name and address of GP;
  • Next of kin or emergency contact details;
  • Contact details such as telephone numbers, address, email addresses;
  • Where you provide them to us, demographic information such as gender, age, marital status, sexuality, ethnicity, employment status, disability, religion, area of residence, and how you heard about our services;
  • Clinical information gathered as part of the referral, assessment and counselling process.

Some of the data we collect is considered to be sensitive personal data under the GDPR.

As a counselling service, it is in the nature of our work that clients will reveal, and counsellors will process, such sensitive data. We are ethically obligated to conduct appropriate client assessments. These considers clients’ physical or mental health keeping in mind the safety and appropriateness of any service we may offer and maintaining accurate client notes. We will only collect, process and store the minimum necessary information.

Reasons why we need information about you…

  • To create an appropriate support plan in line with your needs;
  • To plan, supply and deliver services;
  • To work with and coordinate services with other organisations;
  • To protect you or others from abuse or harm;
  • To help you arrange and receive services when needed;
  • So that external regulators, inspectors and funders can check and audit our services and ensure they meet the required standards;
  • So that we may review, audit and improve the quality of our services and increase their benefit to you;
  • So that we can check our services are accessible to all parts of society.

Our Legal Duty

Bromley, Lewisham & Greenwich Mind as data controllers have a duty to hold and process your information lawfully and fairly.  We have an obligation to ensure the information is accurate and up to date.  It must be held for no longer than is necessary and must be kept secure and confidential at all times.

This service uses the CORE Net software as its database. All paper records are kept locked at all times.

Legal basis for holding and processing information

The legal basis on which we hold and process your data is legitimate interest, as we need the data in order to be able to effectively provide you with a service and to monitor to what extent our services are effectively reaching all parts of society.  Under law some types of data such as ethnicity, disability, religion, medical diagnosis are classed as special category data as it is perceived to be more sensitive.  Where we hold this data we will do so under one of the following paragraphs of article 9 of the General Data Protection Guidelines 2018:

  • Medical diagnosis – paragraph(h) that we are providing health or social care
  • Equality and Diversity information – paragraph (a) that we have your explicit consent or that of a carer where this can be legally given, or paragraph (j) for statistical purposes where consent cannot be obtained. Equality and diversity information is held against your record, but any reporting on it is anonymised.

Whilst holding a Lawful Basis of Legitimate Interest for processing sensitive data, we will also seek clients’ explicit and informed permission (the Lawful Basis of Consent) during referral and assessment stage.

Where consent has been given, you have the right to withdraw this consent at any time.

If the consent will not be given for particular information, the clinical team will assess whether the information we hold about you is sufficient to provide you with our services securely and appropriately.

Confidentiality & Sharing Data

Greenwich Counselling Services may share your data between other BLG Mind services in Greenwich.

It may be necessary to share your information with other organisations working to support you, for example care agencies, housing organisations etc.  We will normally gain your consent before doing so.  However, in certain circumstances there may be occasions where it is necessary to share information without your consent.  For example, in circumstances where disclosure is felt to be justified in the public interest e.g. to protect you or someone else from harm. In these circumstances the information shared will always be kept to the minimum necessary.

We may use the feedback information which you have provided to us voluntarily about our service, however your identifiable information won’t be revealed, unless you consent otherwise.

We may use online communication platforms provided by third parties (e.g. Zoom, Skype) and Telephone Service providers in order to deliver Online Counselling sessions. This will be by agreement with clients. Please note that external agencies and software providers have their own privacy policy.

Your rights

Under the Data Protection Act, you have number of rights in respect to your personal data.

Requests can be made verbally or in writing and there may be a fee involved.
To make a request please contact us on Data.Controller@blgmind.org.uk or Data Controller

Bromley, Lewisham & Greenwich Mind, Anchor House, 5 Station Road, Orpington, Kent, BR6 0RZ or call us on 01689 811222.

After confirming your identity, Counselling Services in BLG Mind have one month to provide you with the information.

Third party requests, i.e. from insurers or solicitors, must be accompanied by a consent form signed within the last 6 months.

The right to be informed – You have the right to ask for information about what personal data (about themselves) is being processed and the rationale for such processing.

The right of access – You can access the personal data we hold about you. You may ask to see your personal data and to request a copy of it.

The right to rectification – If you believe that data we hold about you is not up-to-date or is inaccurate you can ask us to make a correction.

The right to erasure (also known as the right to be forgotten) – You have the right to be asked to be forgotten, which means any data we hold on you must be delated or anonymised so that it can no longer be identified as yours. However, doing this will mean that we may not be able to provide a service to you and if you would like a service from us in the future, we will not be able to access your historic records.
Counselling Services reserve the right to refuse erasure of specific information in order to exercise or defend legal claims, and to comply with professional counselling standards.

The right to restrict processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

The right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

The right to object –You have the right to object to the processing of your personal data in certain circumstances.

The right to object to automated processing for decision-making – Automated processing for decision-making is not used in Counselling Service of BLG Mind.

Right to complain – If at any time you think that there is a problem with the way that we are handling your data you have a right to complain to our data protection lead who can be reached at Data.Controller@blgmind.org.uk

You may also complain to the Information Commissioners Office at www.ico.org.uk.
The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Helpline number: 0303 123 1113

Retention and disposal of data

If you are a client of our service your case file will be archived for 6 years from the moment of ending your counselling or group therapy. After that time all your data from this period of counselling will be securely destroyed from our paper and electronic records.

If after making a referral you do not become an ongoing client of our services
(you didn’t attend initial assessment nor any group session or counselling session), we will securely destroy your details within 12 months since the referral was made.

More information

More information can be found in our Privacy Policy which can be found at www.blgmind.org.uk/privacy.

Alternatively, if you would like us to send you paper copies, please phone 01689 811222.

 

Date of last update: 11 of July 2023