Privacy Policy.
Social Media Policy
Though therapists are mostly trained to keep their personal lives out of the consulting room for the benefit of their clients, the availability of information about us on the internet means that this isn’t always possible. Furthermore, therapists need to make their own choices about their involvement in social media, how publicly available their online presence is, and to be aware of how their online presence can affect their clients. This document is based on our own choices with regard to social media and we ask all therapy clients, whether face to face or online, to read through this document.
Public activities
Our duty of care to our therapy clients and our professional commitment to confidentiality means that we only talk about clinical work in general terms publicly. You will have signed a confidentiality agreement with Mind Work UK when you become my client and we take this very seriously.
Keeping boundaries
As therapists, it is ethically important for us to make sure that relationship boundaries with clients are clear. Therapists do this to protect both their own interests as well as those of their clients. As part of these boundaries and to ensure the success of therapy, we will avoid ‘dual relationships’ where possible (for example, a friend being a client). The very nature of an online presence can blur these boundaries, so it is important for us to be as clear as possible about how boundaries may be challenged in an online environment.
Facebook and LinkedIn
We maintain personal Facebook and LinkedIn accounts. Our aim to keep our personal Facebook account as private as possible and it would not be appropriate to be Facebook ‘friends’ with former or current therapy clients. You can, however, follow our professional Facebook page where we maintain a clinical presence, sharing related links and stories that may be useful to current or prospective therapy clients. It would also not be appropriate to add current or former clients as connections on oue personal LinkedIn accounts.
Interacting with your therapist
Social networking and other online activities are increasingly becoming a part of our daily lives and as a result you may wish to share your stories and experiences with your therapist in between sessions or after your therapeutic relationship has ended. Should you wish to do this, you are welcome to contact us via email or via the professional Facebook page but please note that we will not generally reply to messages in between therapeutic sessions.
Reviews and Testimonials
You are welcome to leave a review on Google. Should you encounter something about us online that concerns you, please discuss it with Garry or Debi.
General Policy Between Therapist & Client
When outside of the therapy room, any contact should ideally be made via email, text message or telephone call.
If we should see you outside of the the therapy room, we will not acknowledge that we know each other for your confidentiality. Should you wish to acknowledge us, that is fine and we will engage appropriately.
All therapy sessions, emails, text messages and recordings made are strictly confidential and will not be shared with anyone without your explicit consent. This is unless we believe you or someone else are in imminent danger. If asked by high court, the police or other legal figure to provide information, we may be obliged under the legal system to do so.
Data Management and Retention.
Therapy client data GDPR: As from 25th May 2018, under the General Data Protection Regulations (GDPR) Debi Hall and Garry Lanes are required by law to inform you (as a current therapy client, or potential therapy client) about how we process and keep safe the data we hold that pertains to you.
We are also required to gain your explicit consent to our holding and processing your data in certain ways (as detailed below).
We take confidentiality and privacy very seriously and are bound by a code of ethics.
What therapy client data GDPR is held about you?
We keep certain data so that we can work safely and professionally with you.
The therapy client data GDPR we hold may include:
1. Your name and address
2. Your phone number and email address
3. An emergency contact’s name and phone number
4. Your GP name and contact details
5. Relevant medical information
6. Session notes/audio recordings
7. Payment information
8. Our emails to you, and yours to us
9. Any text or WhatsApp messages that were sent between us.
10. Invoices
You have the right to know what therapy client data GDPR we hold, why we hold it, and for how long we hold it.
You also have the right to view it, and to ask for changes to be made.
When sensitive data is to be destroyed, it is shredded and disposed of securely.
If we discover there has been a data breach of your personal information that could put you at risk, we will undertake to tell you and the ICO (Information Commissioners Office), within 72 hours.
How long is your data kept for and why?
1. Your name and address
How we keep this data
We keep your name and address in paper form in a locked filing cabinet. These are kept separate from your session notes.
Our clinical supervisors have your first name and phone number in paper form, kept in their locked filing cabinet.
Why we keep this data
This is required by our professional liability insurers.
How long we keep this data
Our professional liability insurer advises that we keep this data for seven years. After that time it is destroyed.
Our clinical supervisors will destroy the data when we finish our work.
Who sees the data
Only your therapist. Our clinical supervisors will see your first name but not your surname or address.
2. Your phone number and email address
How we keep this data
We keep your phone number in our mobile phones under an identifying code, not your name. Our phones are locked with a passcode when we are not using them. Your email address is held in our email address, which is secure, encrypted and is password protected.
Neither our computers nor our phone are shared with anyone else, unless it is required by a technician for maintenance.
We also keep your phone number and email address in paper form in a locked filing cabinet. These are kept separate from your session notes.
Our clinical supervisors have your first name and phone number in paper form, kept in a locked filing cabinet.
Why we keep this data
This is needed in case we have to contact you (for example for rescheduling sessions or sending an invoice).
Our clinical supervisors keep this data so that you could be contacted in case we became suddenly incapacitated through a health crisis or other emergency, as required by a clinical will.
How long we keep this data
We will remove this data when we have finished our work, unless you tell us that you would like us to retain it in case we work together again in the future.
Who sees the data
Your therapist and their clinical supervisor.
3. Emergency contact’s name and phone number
How we keep this data
We keep this data in paper form in a locked filing cabinet along with your name and contact details.
Why we keep this data
It is unlikely that we would ever use this information, but we hold it in case we become concerned for your welfare and cannot get hold of you. You and your therapist may agree together on some other reason that we might contact this person, based on your best welfare.
How long we keep this data
When we finish working together, this data will be deleted, unless you and your therapist decide to make other arrangements.
Who sees the data
Only your therapist.
4. Your GP name and contact details
How we keep this data
We keep this data in paper form in a locked filing cabinet along with your name and contact details.
Why we keep this data
We may agree together on some reason that your therapist might contact your GP, based on your best welfare, for example discussing diagnosis, treatment plan or safety procedures.
How long we keep this data
When we finish working together, this data will be deleted.
Who sees the data
Only your therapist.
5. Relevant medical information
How we keep this data
We keep this data in paper form in a locked filing cabinet along with your name and contact details.
Why we keep this data
It may be relevant to share certain medical information when:
(a) Your mental health history, diagnoses etc. may inform my treatment plan to make it more appropriate for you
(b) There is any risk that health conditions such as seizures, diabetes, etc. may impact a session
(c) Your medications may affect our work.
(d) You have any allergies that we should be aware of in order to keep you safe.
How long we keep this data
When we finish working together, this data will be deleted.
Who sees the data
Only your therapist.
6. Session notes/ Audio recordings
Notes may include dates and times of attendance, and brief notes on important themes from the session. We do not keep detailed session notes. We keep a ‘clear desk’ policy, which means that session notes and other information are not left unattended. Please note that we may record sessions if we think it will be of benefit to therapeutic success. This will be discussed with you prior to doing so and if you do not consent, then we will refrain from recording the sessions. We will ask you to sign a separate form of consent if you do agree to sessions being recorded.
How we keep this data
We keep brief session notes in paper form in a locked filing cabinet. Your name or other identifying details are not kept with your session notes; only a code is used.
Any recordings will be deleted once sent to you.
Why we keep this data
Notes may remind us of important points we want to be sure to remember to discuss in our next session, and/or in supervision.
How long we keep this data
After the work has been discussed in supervision, we may destroy any notes (or parts of notes) and delete recordings that our supervisors and we do not consider necessary to keep for longer.
The current policy is to destroy session records seven years after our work finishes.
Who sees the data
Only your therapist.
7. Payment information
How we keep this data
We make a note of payments you have made, on a password-protected financial spreadsheet for our business. We may also outline invoices and record payments in a secure, password protected file on the cloud, but under a code rather than your name.
Why we keep this data
As a small business owner, we are required by law to retain certain financial information, primarily for tax purposes.
How long we keep this data
We keep financial information for 7 years as advised by HMRC.
Who sees the data
Banking transactions may be viewed by Mind Work, employees of the bank and tax officers (HMRC).
When payment is made via BACS, your account name or reference (or the name of the person who is paying) may show up on our online or paper bank statements. You have the right to discuss alternative payment options with Mind Work.
8. Your emails and texts
How we keep this data
We may delete emails after we have noted the contents (for example, emails around scheduling). Any emails that we consider necessary to keep are retained in our email account, which is encrypted and password protected.
If you would like to communicate via text, for example regarding rescheduling appointments, you can do so via normal text message or WhatsApp. Our phones are passcode protected and not accessible by anybody but ourselves.
Please note that applications such as FaceTime and Messenger, are not recommended due to confidentiality and privacy issues. We do not use these with clients.
Why we keep this data
We may keep emails if we consider it clinically necessary.
How long we keep this data
We will delete emails when our work ends, unless they form session notes (in which case, see above).
Who sees the data
Only your therapist.
9. Invoices
How we keep this data
We create invoices on our computers using Microsoft Word, and then export as pdf. Invoices are kept as password protected documents on our computers and on the Cloud, which is again password protected.
Why we keep this data
We use the invoice to create the next one (in the case of ongoing work) so that we can revise and update it with new information.
How long we keep this data
We keep the invoice for a short time whilst we monitor payments (usually this is one month). Once payment has been made, and any further invoice has been created, we delete the invoice.
Who sees the data
Only your therapist.
Changes to the Policy
Mind Work will notify you of any changes that we may make to this policy in the future.
· Please read and sign to indicate your consent. You may print a paper copy, or copy and paste digitally.
· If you do not wish to give your consent, you have the option to discuss with your therapist, and it may be possible to create a bespoke agreement between us.
· You have the right to withdraw your consent at any time. We would need to discuss what this might mean in practice, with the primary aim being to keep you safe. However there may be certain situations that require certain information to be retained, and we may need to seek legal advice in this case.
· If you agree to give your consent for Mind Work to hold and process your data as stated, please sign, date and return to your therapist by hand, by post, or email to the email account: support@mindworkuk.com
Please sign and date below if you consent to the client data GDPR points above.
☐ I agree to Debi Hall / Garry Lanes holding, controlling, processing and storing my data as stated.
Signed:
Print name:
Date:
If you have any other questions regarding how your client data GDPR is processed and handled, please do not hesitate to discuss with Mind Work UK.