Privacy Statement: 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.
Sessions outside: Where sessions are delivered outside, we shall both take reasonable steps to ensure confidentiality. In practice this requires us to be aware of members of the public and adjust conversation and our path accordingly. If we cross paths with someone I know, I may briefly acknowledge them, and continue walking. I shall not introduce you and you should avoid introducing yourself. If we cross-paths with someone you know, I will stay quiet and keep a distance, and allow you to manage the moment, but again not feel you have to introduce me.
Forest Bathing/ Climate Café: These are not delivered as psychotherapy services, but I do still have a responsibility under GCDP. With events booked via Eventbrite I ask for your name, email, and mobile phone number. These are stored with Eventbrite who have their own GDPR and policies around data sharing. I may use your email address to update you about an event you are booked onto or advise you of future events, but this is never shared with a third party.
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 27th September 2021