Privacy Policy
Caladh Counselling and Psychotherapy is a counselling and psychotherapy service provided by Rory Ross. We are committed to protecting your privacy. Please read the following in order to learn more about our information collection and use practices.
‘Data controller’ is the term used to describe the person or organisation that collects and stores and has responsibility for the personal data. In the terms set out in the legislation, Rory Ross is the ‘data controller’ and registered with the Information Commissioner’s Office.
Section One
This Website
Cookies
Cookies are wee bits of data stored in your browser, they would normally keep track of your selected settings and the actions you take on the site. All About Cookies.
The following links explain how to access cookie settings in various browsers:
To opt out of being tracked by Google Analytics across all websites, visit this link: http://tools.google.com/dlpage/gaoptout.
Website Hosting
This site is hosted on the Wix.com platform.
Wix uses analytics software tools to measure and collect session information, including browser information, Internet protocol (IP) address, page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. Any data you enter into the website may also be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall. For full details of Wix.com’s privacy policy visit https://www.wix.com/about/privacy
Section Two
Purpose for Processing
When you request counselling or otherwise provide your personal details to me, this information is collected and stored for the purpose of responding to your query and providing you with the requested service. In order to provide you with the best service possible, and to comply with our ethical and legal responsibilities, we need to hold your personal contact details and records of your therapy sessions. The information collected in this way is used for no purpose other than this.
We have set out in detail the purposes for which we process your personal data in the Uses of your data section.
Section Three
Where Do We Get Your Personal Data From?
We receive personal data about you from the following sources:
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Your email(s) - submitted by you.
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Your registration/intake form - submitted by you online, or on paper.
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Occasionally from third-party sources (e.g. GP, family, friends).
Section Four
Legal Bases
We keep the personal data you provide for three years after your last contact with our Service. adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003. We also adhere to the ethical guidelines regarding protecting client privacy and confidentiality set by the British Association for Counselling and Psychotherapy (BACP).
There is more than one legal basis for the use of your information. The appropriate legal basis for each purpose of use is noted against each category in 'Uses of Your Data' section. A brief explanation of each legal basis is noted below:
Article 6 (1) (a), Consent - on specific occasions, we will only process certain data if you consent e.g. when you attend a consultation appointment, we ask you to complete a registration form.
Article 6 (1) (b), necessary for the performance of our Therapeutic Contract - we will process your data to enable us to meet our commitments to you in providing a confidential counselling service.
Article 6 (1) (c), when processing is necessary for the Legitimate interest of the counsellor over the interests of the data subject (e.g. when we record concern expressed about a client by a third party).
Section Five
Sharing Information
We will not share any information about you with other organisations or people, except in the following situations:
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Consent – Caladh may share your information with professional carers or others whom you have requested or agreed should be contacted.
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Serious harm – If we believe you or a third party is in serious danger, we may share information with other appropriate services e.g. your General Practitioner (GP), NHS services, Police and other emergency contact.
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Compliance with law – Caladh may share your information where required to by law or by the regulations and other rules to which counsellors are subject.
Section Six
Storing Information
All information you provide is stored as securely as possible. All electronic records are stored on reputable service providers using secure end-to-end encrypted cloud storage. No one, including the storage provider, can access our files other than Caladh. This advanced encryption is secure against all known attacks. We access the information through a Virtual Private Network (VPN).
Communications: We use an end-to-end, zero-access encrypted email provider, I cannot guarantee the security of your data transmitted from you to Caladh via your email; any transmission is at your own risk. Once I have received your information, I will use strict procedures and security features to try to prevent unauthorised access.
Your identifiable personal information is kept separately from session notes and other descriptive material. Client notes and other documentation are destroyed 3 years after the end of counselling.
If you write to us in Gaelic, we may be using a third-party translator to translate your message into English and our response back into Gaelic.
Ma sgrìobhas sibh litir no post-d thugainn sa Ghàidhlig, tha e comasach gun cleachd sinn eadar-theangair airson do theachdaireachd eadar-theangachadh bhon Ghàidhlig gu Beurla agus freagairt air ais dhan a’ Ghàidhlig.
Section Seven
Your Rights
You have the right to ask me to provide a copy of the information held by me in my records. You also have the right to require me to correct any inaccuracies in your information. If you would like to do this, please contact me via the email address listed.
You may withdraw your consent for me to hold and process your data at any time. However, if you do this while actively receiving counselling services from me, these services would have to end, and some information must be retained for legal and insurance purposes.
Section Eight
Complaints
If/when a complaint is received, all the information you have given to me is recorded. This information will be used to resolve your complaint.
If your complaint reasonably requires contact with a third party, I may decide to give some of the information contained in your complaint to said third party. This would be done as infrequently as possible, but it is a matter for Claladh counselling and Psychotherapy’s sole discretion as to whether information is given, and what that information is.
I may also compile statistics showing information obtained from this source to assess the level of service I provide, but not in a way that could identify you or any other person.
If you complain about any of the content on my website or in any leaflet, I shall investigate your complaint. If I feel it is justified or if I believe the law requires me to do so, I shall remove the content while I investigate.
If you have a complaint about how I handle your personal data please do not hesitate to get in touch by email at contact@caladhtherapy.com.
If you want to make a formal complaint about the way I have processed your personal information you can contact the ICO which is the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint.
Section Nine
Contacts
To exercise all relevant rights, queries or complaints please in the first instance contact me at contact@caladhtherapy.com
You can contact the Information Commissioner's Office on 0303 123 1113 or via the website (ico.org.uk) or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
If you have any questions please email us at: contact@caladhtherapy.com
Section Ten
Changes to this Policy
This privacy notice may be updated from time to time, so please check occasionally for any updates.
Current Version: 14 October 2023
Uses of Your Data
Registration/intake form
Source of Data: Client Registration form.
Legal Basis: Performance of Contract.
Retention Period: 3 years after last contact.
Specific Purpose: We collect this information to keep a summary record of information shared by you.
Case Notes
Source of Data: Generated by Counsellor
Legal Basis: Performance of Contract.
Retention Period: 3 years after last contact.
Specific Purpose: We keep a summary record of information shared by clients, by session, in order to deliver an ethical counselling service
Emails
Source of Data: clients, third parties
Legal Basis: Performance of Contract.
Retention Period: 6 months or once query is resolved email(s) deleted.
Specific Purpose: Responses to requests for counselling and queries about the Service
Client Information
Source of Data: Occasionally received from a third party
Legal Basis: Pre-contract
/ Legitimate interest
Retention Period: When dealt with or 3 years after last contact (if client has accessed the service)
Specific Purpose: To record concern expressed about a client.
Counsellor's
supervision
Source of Data: Counselling sessions
Legal Basis: Performance of contract
Retention Period: No Notes retained.
Specific Purpose: In line with professional requirements, counsellors may discuss counselling sessions with a supervisor external to the Service. The identity of the client is not revealed. The purpose of supervision is to help the counsellor reflect on their work with clients. https://www.bacp.co.uk/events-and-resources/ethics-and-standards/ethical-framework-for-the-counselling-professions/.
Evaluations
Source of data: Occasionally received from a third party
Legal Basis: Pre-contract
/ Legitimate interest
Retention Period: 1 year
Specific Purpose: Survey to monitor user feedback, inform service development.