Cecily Criminale, MS, MEd, MA, Registered Member BACP (Accred.), AccCOSRT
This document explains how I protect your privacy. In the event we agree to a contract for therapy, this will be stated in our contract and reviewed during the initial consultation. I am registered with the Information Commission (ZA205272). Contact the Information Commissioner If you have concerns about how your personal data is held/stored: www.ico.org.uk, 0303 123 1113.
Confidentiality & Data Protection
Are these sessions confidential?
Confidentiality is complete except in circumstances that include risk of serious harm to self or others (including potential or actual harm to a child), disclosures required by law (i.e. money-laundering, terrorism, drug trafficking, murder), or when required to do so by court order. I also reserve the right to breach confidentiality and to use my session notes in order to address any grievances.
All work is supervised. This is an accepted part of good practice and is a professional requirement. The purpose of supervision is to provide additional insights into client care and to secure an outside view for quality control and client protection. Your identifying information will never be disclosed. Information a supervisor receives is treated as confidential and is subject to the same ethical criteria as our sessions.
What information is kept about me and who has access?
As the Data Controller I am the only person who has access to session notes and any forms we use as part of therapy. Sharing of this information with someone other than yourself requires your express written permission or a court order. Notes I make regarding relationship therapy sessions will only be released if all individuals involved in the therapy give written consent.
In the event of my incapacitation (e.g. illness, injury), your contact details and files will be accessible by my Therapeutic Executors. This is strictly for the purpose of ensuring you are informed, advised, and can continue to access your personal information. During the duration of therapy, your name and contact detail is held, confidentially, by the Executor and is provided to via a password protected email.
You have the right to request a copy of session notes and forms. Upon written request, this will be provided to you within 30 days and can be provided to you in an electronic format on a USB stick. You also have the right to rectify any personal data held by me. If you wish to object to any information contained within the session notes, your objection will be filed along with the original session notes.
Please be aware that if you pay via electronic transfer or card reader there is a record of transaction for services provided. The record of payment is to The Richmond Centre Ltd, my company name, though I trade as Cecily Criminale. If paying by electronic transfer, we will discuss creating a ‘code’ that designates it is you to me but may be less obvious to third parties (banks, accounting software companies, and accountants).
How is my information stored?
Any forms completed during therapy, and brief notes of our session are kept as hardcopy documents in locked files or in a password protected electronic cloud, depending upon our contract. These documents are held for seven years from the time of termination of therapy or after resolution of a dispute after which the documents are destroyed. These are held for this time as advised by accrediting agencies and for the purposes of helping to address complaints should they arise. Hardcopy (paper) email and text exchanges may also be kept as part of these records.
It is common for contact to take place via electronic medium such as email, phone, or text. Messages received via these media are deleted at the end of each month. These media are not generally encrypted and as such I would not recommend exchanging detailed information of a personal nature. In the event we undertake remote counselling, we will use an encrypted programme.
How is my information used?
Counsellors’ notes are considered to be a memory aid of reported events. As such they are generally not admissible by courts. I will not write about our work without your express, informed, written consent. Your data will not be shared by me with third parties.
Cecily Criminale, MS, MA, MEd, BACP Registered Member (Accred.), AccCOSRT