General Data Protection Regulations (2018)
Role: Andrew Jenkins, Psychotherapist in private practice. Trading as HUD People Development Ltd.
Data records (electronic): At our first session I will ask for your full name, date of birth, home address, contact telephone number, and contact email address.
This data is stored on a cloud-based IT system accessible on my phone, tablet, and desktop computer. All these devices are password protected. This data is used solely for the purpose of maintaining contact between us.
Data records (paper): I do not usually keep notes of sessions, but if on occasion I do, these will be my reflections on a session and not your personal data. The notes are anonymised and not traceable to you.
This data is written in a notebook, which is stored in a locked filing cabinet, at my home-office.
Time frame: Data records will be kept for the duration of our work together, and for up to six-months after our work together has concluded. At that point, electronic data is deleted from all devices and from computer back-ups. Paper records are shredded.
Online/ telephone sessions: Sessions can be delivered by telephone or online using Zoom or Facetime. I shall take every reasonable step to ensure the technology used to deliver these sessions remains secure. Under no circumstances are they recorded, wholly or in part. Similarly, you do not have my permission to record sessions, wholly or in part.
Data Sharing, Professional Executor: With your best interests in mind, it is good practice for me to have two professional executors. These are colleagues who have similar psychotherapy experience as myself. They are equally bound by GDPR, and professional standards around confidentiality.
In the event of my sudden death or becoming incapacitated, these colleagues have access to your name, telephone number, email address, and home address. These details are kept as a paper note, in a sealed envelope, in a locked filing cabinet, at my home-office.
They will contact you, ideally before your next session is due, to explain the situation. In time you may find them helpful in discussing ongoing requirements for your psychotherapy.
Data Sharing, other: Your personal data will never be shared with a third party, other than my professional executors as described above.
Subject Access: You have a right to request access to any of your personal data I hold in storage. I shall respond within one month. There is no fee for this.
Andrew Jenkins 1st June 2020