Privacy Policy
I am committed to protecting the privacy and security of any personal information in accordance with NCPS guidelines and ethical framework and current GDPR (General Data Protection Regulations) arrangements. I take care to protect the privacy of my clients’ details when they communicate over the phone, via email or through this website.
This policy sets out information about what data I collect, how this is stored, and what rights clients and website visitors have over any personal information handed over to me.
In accordance with GDPR regulations, the data controller is Tracey Woolf. I am registered with the Information Commissioner’s Office (ICO) under reference ZB018745.
Contact details
Name: Tracey Woolf trading as Tracey Woolf Counselling
Phone number: 07980 976624
Email: hello@traceywoolfcounselling.com
The type of information I collect
CLIENTS AND ENQUIRIES
Most of the personal information I process is provided to me directly when a person makes an enquiry via email, over the phone, or via the website, and when I first begin work with a client. This includes:
Contact details
GP Surgery
Next of Kin
Session Notes
THIS WEBSITE
I also process personal information indirectly via this website, which uses cookies and collects personal data to run the website and learn about site activity in an aggregate manner. This information is shared with the website analytics provider Squarespace. To read more about how this website works and how users can give consent or refuse non-essential cookies, please refer to the Cookie Policy.
Data collected includes information about a user’s browser, network, and device, web pages a user visited prior to coming to this website, and their IP address. Squarespace needs the data to run this website, and to protect and improve its platform and services. Squarespace analyses the data in a de-personalized, aggregate form. Additionally, information collected may include details about the visitor’s use of this website, including clicks, internal links, pages visited, scrolling, searches and timestamps.
LAWFUL BASIS
Under the GDPR, the lawful basis I rely on for processing the above information is consent. You are able to remove your consent at any time. You can do this by contacting Tracey Woolf at hello@traceywoolfcounselling.com.
How I store the information
CLIENTS AND ENQUIRIES
Contact and personal information will be stored on a password controlled online management system.
I will destroy data (contact details and session notes) when they are no longer useful, usually after the work has ended, unless otherwise specifically agreed with a client.
THIS WEBSITE
Personal data collected for website analytics is stored by Squarespace, who acts as Data Processor. Their Privacy Policy is available here.
Confidentiality notice
Confidentiality may, on rare occasions, need to be breached if I feel ethically bound to seek assistance on a client’s behalf or on behalf of others. This would be if I am made aware that a client is at risk of harm or causing harm to others, or others they refer to are at risk of harm. This will always, where possible, be in discussion with a client unless circumstances prevent this. In rare cases such as this, I will, where appropriate, endeavour to inform a client about what has been communicated and to whom. The instances where I am bound by law to disclose information are those relating to drug trafficking, drug money laundering and acts of terrorism.
As a professional requirement, I attend individual and peer group supervision to discuss and explore aspects of my practice. Clients are not identifiable within this process. My supervisor also works in adherence to the BACP/NCPS Ethical Framework as do my peer supervision colleagues who I will sometimes share elements of my practice with.
In the event of me becoming incapacitated by illness or death, I have a “counsellor’s will” that will be activated and responded to, as per my instruction, by a trusted colleague who is also bound by the BACP/NCPS Ethical Framework and is familiar with the GDPR (General Data Protection Regulations). I will review this privacy notice annually, unless something significant arises that means I need to address anything sooner.
Please refer to the Counselling Agreement for further details.
Agreements and rights
All clients are required to consent to the bounds of the Counselling Agreement and to client data collection as per this policy. Clients will be notified of any changes to this policy and have the right to withdraw their consent at any time. Clients also have the right to ask for their data to be deleted or amended. You can ask for a copy of your data in a subject access request and Tracey Woolf will provide you with this, free of charge, within 30 days.
In general, under data protection law, you have rights including:
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
Your 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.
Please contact Tracey Woolf at hello@traceywoolfcounselling.com if you wish to make a request.
Data breaches
In the event of the discovery of a data breach, Tracey Woolf will report the breach to the Information Commissioner’s Office of the Data Protection Agency within 72 hours.
How to complain
If you have any concerns about my use of your personal information, you can make a complaint to me at hello@traceywoolfcounselling.com.
You can also complain to the Information Commissioner’s Office if you are unhappy with how I have used your data. The ICO’s address is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
April 2021