The General Data Protection Regulation
Updated May 2018
by Ruth Hubbard and explains how she uses, maintains and discloses
the practice, website and services offered by Ruth Hubbard, online,
by telephone or within her private practice.
Clients will be provided with a
paper copy and will be asked to sign as a statement of understanding
of the contents.
Personal Information I collect:
Preferred contact number
Details of presenting issue
Medical conditions relevant to counselling
Client expectation from counselling
How I store information:
Handwritten notes pertaining to
sessional content & personal details are kept separate in a locked
cabinet in a locked room.
Smart phone: My smart phone is
locked & is only accessible using a password or finger print. I
store your contact number by first name only - if this is
unacceptable please request and I will remove your name.
Email / Texts: Email addresses are
stored in my Gmail account or protonmail account. Txt messages are only assigned to first
names only - if this is unacceptable please request and I will
remove your name.
Website. No personal information is
stored on my website other than to momentarily collect & send
enquiries to my gmail account for initial contact purposes.
Third party websites: Clients may find content on my
website that link to the sites of other third parties. I do not
control these sites which have a link to mine and I am not
responsible for how they collect, store or use information
Contract / Agreement form.
Privacy statement signed by
Client sessional notes, kept for 5
years to comply with Insurance policy terms.
How I may share your personal
Supervision: I attend monthly clinical
supervision to ensure my practice remains safe & ethical. Session
details & clients initials may be shared with my Supervisor.
Therapeutic Will: Your name & contact details will
be shared with my Therapeutic Executor so that in the unlikely event
of my sudden death you can be contacted should you still be in
therapy with me. My Therapeutic Executor will sign a confidentiality
The content of the sessions are
confidential, apart from in exceptional circumstances as follows:
- I am concerned about your own or someone
- I am made aware of serious illegal activity or
- You disclose any historical, recent or current
acts of abuse upon a child or vulnerable adult.
- Any concerns or declarations that would lead me
to believe there is a safeguarding issue.
Any disclosure of any confidential
information will be restricted to relevant information, conveyed
only to appropriate people and for appropriate reasons. In
this event, wherever possible, your permission will be sought before
Erasing your information:
All electronic enquiries are erased after 3 months. All contact numbers
are erased 3 months following the cessation of therapy. Emails will
be printed off and kept on record for the aforementioned 5 years but
will be deleted from my account 3 months after last session.
I hold your written information for
up to 5 years following the cessation of therapy. This is so I have
a reference should you decide to return to therapy in the
future, I am alsoobligated to keep these files for to comply with the terms of my insurance.
Right to Access: You have the right
to ask for a copy of your personal information, free of charge, in
an electronic or paper format. You also have the right to ask me to
amend or change any incorrect information about you.
Right to be Forgotten: You have the
right to ask me to erase any information that I hold about you. This
includes your personal information that is no longer relevant to
original purposes, or if you wish to withdraw consent. In all cases
and when considering such requests, these rights are obligatory
unless it’s information that I have a legal obligation to retain. As
stated I have a duty to keep sessional notes for 5 years in line
with my insurance companies policy.
Data Portability: As the client,
you have the right to receive your personal information which you
previously provided, also you have the right to transfer that
information to another party. For the purposes of the General Data
Protection Regulations (GDPR) 2018, the data “controller” is Ruth
Hubbard (Ruth Hubbard, Transformation through talking).