Privacy Policy

Indlela Counselling is a business operated by Ayanda Dlamini-Wolff MBACP (indlelacounselling@gmail.com). Under the Data Protection Act 2018, I am a “data controller”. This means that I am responsible for deciding how I hold and use the personal information I hold about you.

 

Your privacy is very important to me, and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to me. I am registered with the ICO (Information Commissioners Office – ICO Registration No.: ZB601048) and I adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

 

In order to provide you with the best service possible, I will hold your personal contact details and records of your therapy sessions. Please find below important information about how this information will be held and used.

 

How do I collect information about you?

I collect information (including contact information) from you during calls and by email when discussing your needs. If you become a client, I make minimal written notes of our sessions (although I use reasonable efforts not to include identifiable information in those notes such as your name). As a general policy, I keep written (whether electronic or otherwise) records containing personal information to a minimum and regularly delete emails and documents where there is no legal or business need to retain that information.

 

My insurance company requires that I keep some notes for a period of 5 years after the end of counselling or therapy. This means that I cannot erase certain information I hold about you in that period.

I collect, store, and use the following categories of personal information about you:

  • the information you provide to me when you initially contact me (typically name, email and telephone number)

  • the information you provide to me in your introductory call and/or initial assessment session; and

  • if you become a client, the information you provide to me in your client sessions and any communications between sessions.

I may also collect, store and use the following “special categories” of more sensitive personal information if you provide it to me (but there is no obligation for you to do so): (i) information about your race or ethnicity, relationship status, and sexual orientation; (ii) information about your health, including any medical condition, health and sickness records; or (iii) information about criminal convictions and offences.

 

 

How do I use your personal information?

The main purpose for using your personal information is to provide services to you under contract. I will never provide your personal details to a third party without your consent except in the following circumstances:

  • When someone visits my website, I use two third-party services, Squarespace and Google Search Console, to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. I do not make, and do not allow Squarespace to make, any attempt to find out the identities of those visiting my website. I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website. Like most websites we use cookies to help the site work more efficiently - find out about our use of cookies here. No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.

  • I discuss all of my clients in clinical supervision. In such circumstances, I will use your first name but will keep identifying information about you to a minimum. My supervisor is a member of the BACP and UKCP and is bound by the codes of ethics of those organisations.

  • I may undergo courses and/or seek further stages of accreditation with my existing or further professional membership bodies for counselling and psychotherapy. In such cases, I may need to write case studies and provide transcripts of recordings. For clinical supervision, I may also seek to reflect on specific aspects of sessions with my supervisor based on recording(s) and/or transcript(s) of sessions. In all such cases, I will ask for your consent to recording and transcription in advance and there will be a separate audio recording consent form detailing what I do with the recording(s) and transcript(s) of sessions.

  • I may use individual consultants for administrative purposes (for example, if I engage a bookkeeper or accountant, there is a possibility that individual may see your name as part of checking payments). If so, I have a contract with those individuals which places restrictions on when and how they can access your personal information. I do not allow them to use your personal data for their own purposes. I only permit them to process your personal data for specified purposes and in accordance with my instructions.

  • I use third party software (Gmail, Docusign and Acuity Scheduling) which will capture certain information about you when you sign your contract and privacy policy, contact me or book a session. My contract with those companies places restrictions on when and how they can access your personal information. Here are links for the privacy policies of Google , Docusign and Acuity Scheduling. I also use Zoom to conduct online sessions with your recurrent Zoom link being sent via your email address. You can find Zoom’s privacy policy here.

  • In rare circumstances, to my legal professional advisors and / or underwriters in the context of seeking legal advice or in the context of legal action.

  • Where I am required by law, including by court order.

  • As stated in our contract, if I reasonably believe that you or someone else is at serious risk of harm, I may contact a third party for the purpose of preventing harm (for example, by ringing 999, contacting your GP or the police).

 

How long do I keep personal information?

If you become a client, I keep your personal information for as long as you remain client and for 5 years thereafter except where there is a legal or insurance need to retain the information for longer. If you approach me but do not become a client, I will retain personal information you provide for no more than six months. I keep your personal information for these periods for my ‘legitimate business interest’, which means a reasonable use in line with my business activities. I also retain your personal information for that period so that I can show, in the event of a legal or other claim, that I have acted in a lawful and transparent way.

 

Your rights

Where I have asked for your consent to process personal information, you have the right to withdraw your consent. However, I do not typically ask for your consent to use personal information about you as I use your personal information in order provide services to you under contract and for legitimate business purposes.

 

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information I hold about you and to check that I am lawfully processing it.

  • Request correction of the personal information that I hold about you. This enables you to have corrected any incomplete or inaccurate information I hold about you.

  • Request erasure of your personal information. This enables you to ask me to delete or remove personal information where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal information where you have exercised your right to object to processing (see below).

  • Request the restriction of processing of part or all of your personal information. This can include asking me to stop processing your information for a particular period of time.

  • Request the transfer of your personal information to another party.

 

If you want to exercise any of these rights, please contact me in writing (which can be by email). Please be aware that I may nonetheless be required to keep some of your personal information for legal or insurance reasons.

 

How I protect your personal information

I store your personal information using secure physical safeguards and secure IT systems (e.g. password protected computers, back-up drive). Your personal information and client notes are store separately as password-protected files on a password protected computer. Your personal information may also be included in emails or text messages between us, and in the Calendly app if you book sessions online. Access to these is password protected.

 

Contacting me

If you have any questions about this privacy notice or how I handle your personal information, please contact indlelacounselling@gmail.com. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. For more information go to www.ico.org.uk/make-a-complaint.