Privacy Policy

This policy applies to Heather Cowie (data controller) ICO reference number ZB630046 and is relevant to her counselling and supervision services. This policy applies to her practice, website and services; online and in person.

Information I collect and how I use it

In order to offer my counselling service in accordance with legal and ethical obligations I may need to gather and store the following:

Name, address, DOB, contact number and email address GP details
Reason for seeking counselling
Counselling history
Medical information and lifestyle information relevant to counselling
Medications relevant to counselling
Personal details; occupation, relationships, dependents, emergency contact number, relevant religious or cultural information.
If relevant, assessment information such as PHQ9, GAD7 or CORE, or other risk assessments.
Notes of our sessions; which include dates, times, payment information, summary of issues discussed.
If relevant, I may need to complete Safeguarding incident reports, ethical decision making forms or other forms related to our counselling work.

How I store your information

The above information, gathered through intake forms, contracts, assessments as well as sessional notes is stored securely. This will be either through online platforms, on my personal password protected laptop or for paper documents in a locked cabinet in my private property. I have risk assessed each of the digital platforms or tools I use listed below to understand how the data is handled and stored, any risks to confidentiality and how to mitigate those risks as far as possible :

More details:

Physical security: session notes, in-session assessments, and other hand-written forms such as safeguarding forms are stored in a locked cabinet within my private property.
For telephone calls and text messages, I have a separate work mobile phone, which is locked and password or thumbprint protected. If your number is stored, it will be with a first name and a code only.
Emails, document storage, calendar and google meet information is stored in my google account. I have smart features and Gemini turned off.
I do not use any AI tools or automated transcription tools to record, transcribe or summarise our sessions. This is the same whether we are working face to face or online. Should I ever decide to use them, I will seek your explicit, written prior consent before doing so.
I do not use digital note-taking software. Should I ever decide to use one, I will seek your explicit, written prior consent before doing so.
Any recording of counselling sessions in any way (audio, video, screenshots) would only be done by explicit consent.
I use Jotform to securely collect contact details and counselling agreements. Data is encrypted in transit and stored on secure servers located within the EU.
Website: I use Wix to host my website. I have a cookie banner in place which allows visitors to accept or decline non-essential cookies. Any information collected via contact forms is not published on my web page and is treated in line with all data as per this policy.
Clients may find information about me on third party websites, such as the BACP directory. I do not control these sites - and I am not responsible for how they collect, store or use information.

Your information is kept for a period of 5 years following the end of our work, as specified by my insurer. In the case of a young person under 18 years records are kept for 5 years after the date they turn 18. After this date, all records will be destroyed securely.

How I may share your personal information

I attend monthly clinical supervision to maintain ethical and safe practice. I do not share identifiable information but I may discuss client’s presenting details. My Supervisor is a counsellor and bound by professional confidentiality in the same way as myself.
If your health is at serious risk I may share your details with a healthcare professional, such as a GP or mental health team.
I have a Therapeutic Will. In the event of my death or serious illness, my Therapeutic Executor (a qualified counsellor and supervisor who will observe confidentiality) may contact you if you are still in therapy. They may recommend alternative sources of support.

Use of AI tools

I may use AI tools to support my practice but I will not enter any identifiable client information into AI or any other digital tools (apart from those listed above) without your written prior consent.
I do not outsource my decision making to AI and remain responsible for critically evaluating any AI output and decisions based on its suggestions.

Your rights

You have rights regarding the information I hold:

• To request a copy of the information I hold about you. This is facilitated by making a formal request. To do this please email me and information will be provided to you within 30 days.

• To have your records amended, corrected or supplemented (e.g. change of name and address).

• Erasure of Data. Under GDPR you can request your data be erased. However there are exceptions to this. In the case of counselling records, insurance companies and ethical bodies ask for records to be available for the period of time as outlined above.

In the event of a complaint regarding data please email me and hopefully we can resolve the issue. I will acknowledge receipt of your complaint via email within 24 hours and investigate your issues. I endeavour to carry out this investigation within 30 days and respond to you via email.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection. Website: www.ico.org.uk

Contact

I will contact you about appointments or to advise of any changes to my service by email, telephone or text.
If exceptional circumstances arise for either of us, or we need to make contact for another reason, I suggest we send a message to arrange a time to speak by telephone in order to protect confidentiality.
When I am working, my phone is on silent so if I miss a call from you I aim to respond within a working day.
My normal working hours are Mon-Wed 9-6pm.