The General Data Protection Regulation (GDPR) is concerned with the personal information about you that I collect, store and share. This information details Dr Rachel Seymour’s GDPR Privacy Policy.
I am registered with the Information Commissioner’s Office (ICO) which safeguards your data protection and information rights.
Personal Information I will Collect
As a psychologist I will collect both personal and sensitive data. The reason I collect your personal information is to enable me to deliver psychological services (assessments / treatment / consultations or liaison with other involved professionals). Information is collected from the point of initial contact (which might be email, website contact page or phone call) as well as during the initial assessment session and any subsequent therapy / consultation sessions. The information I collect may include the following;
· Name
· Biological sex
· Age
· Date of Birth
· Relationships
· Occupation
· Address
· Telephone / SMS number / WhatsApp contact details (plus permission to send SMS and WhatsApp message and leave voice messages)
· Email address
· Chosen emergency contact (name, phone number and relationship to you)
· Psychological therapy history including any current or historical psychiatric diagnoses.
· Medical conditions relevant to psychological therapy
· Prescribed medication
· Current psychological difficulties
· Historical psychological difficulties
· Lifestyle and social circumstances
· Risk information such as previous suicidal behaviour and/or a history of self-harm and alcohol / substance use / misuse
Information Storage
I have implemented technical measures to ensure your personal and sensitive data remains secure. Your information may be stored in the following ways:
· Paper: written notes which will include the initial email you sent or website contact sheet, therapy contracts, assessment record, brief session notes, Terms of Engagement / Privacy Policy and client code (linking documents).
· Smartphone: I may store your contact information in an anonymised way plain-text note app that backs up to a secure iCloud. Your telephone number (using your initials only) may be stored in SMS or WhatsApp should we exchange messages this way. Please be aware that if you have a WhatsApp profile picture as your face, it may show up when you make contact with me via Smartphone and therefore you are potentially identifiable.
· Email / SMS / WhatsApp: your email address and correspondence will be stored in our email accounts by nature of you contacting my service. Electronic correspondence will also be held by the corresponding app (Mail, Phone’s SMS, WhatsApp).
· Reference to fee payment details (e.g. bank account holders): will be held via digital record on my banking apps and accounting apps (e.g. Quickbooks) for the purposes of accounting and taxation which is now required by HMRC.
· Website: Dr Rachel Seymour’s website stores information you provide in the contact form at the time of your enquiry so I am able to respond to you. You will be asked whether you agree to the Privacy Policy when completing the contact form. It is your choice how much personal information you share with me at this stage. I may respond to your enquiry by email / phone and you will be able to share more personal information with me then.
· Signal / online video consultation platforms: These platforms will store data relating to your contact details used to initiate the consultation.
· Dropbox: Should you wish for us to share large documents I may utilise Google Drive / Dropbox as a shared Dropbox account and all the information shared will be held by us and Google Drive / Dropbox.
· Audio-recordings: Any audio recordings of our sessions would only occur with your expressed permission. They will be stored on a secure voice recorder until they are uploaded onto a hard drive / iCloud or Google Drive / Dropbox (as above). They are then deleted from the voice recorder. This would usually be for the purposes of supervision / therapy accreditation and in this case your explicit consent would be sought. In this instance, the recording may be sent to a 3rd party accredited supervisor (e.g. via Google Drive / Dropbox). If it is considered appropriate for you to audio-record our sessions, please be advised that these are for your own personal use and not to be shared with any other parties or uploaded to other platforms / internet. Should any violation of this condition occur, this would represent a violation of the boundaries of our therapeutic agreement and may result in therapy being terminated or legal action.
· Hard drive / iCloud: I will store brief electronic notes of each client contact for the purposes of treatment planning and record keeping electronically on an encrypted hard drive which is backed up onto iCloud.
How I may Process and Share your Personal Information
· Supervision / Accreditation: I have regular supervision with other qualified psychologists and therapists. Supervision is to ensure I am adhering to professional standards and evidence-based ways of working. Once audio recordings have been used for supervision / accreditation they will be deleted (as above).
· Therapeutic Will: Your name and contact details will be shared with my Therapeutic Executor. This is so you will be contacted in the event of my death, should you still be in therapy.
· Emergencies: If your health is in jeopardy I may share your contact information with an emergency healthcare service (e.g. Mental Health Crisis Team). If I have become aware of your intent to cause harm to yourself, another person or organisation (e.g. terrorism) my professional codes of conduct and the law may require that I inform an authority without seeking your permission. In such a situation, the law may require that I share your personal information without your knowledge (known as whistle-blowing). I will take details of your chosen emergency contact person by initial assessment and if you become unwell in your session or are unable to safely leave, I will contact them on your behalf.
· Erasing Your Information: When we have finished working together, I will retain your written information for up to seven years after the last contact with you. This follows professional guidance from the BPS for Independent Practitioners and is, for example, so that we have a reference of our work in situations such as you returning to psychological therapy in the future or in order to provide continuity of care (e.g. if referred to an another healthcare professional). After this time has passed your paper records will be securely and confidentially destroyed. Electronic data (e.g. reports) will be retained for up to 20 years after the last contact. Audio and video recordings will be deleted if no longer required for purposes of supervision / assessment / accreditation.
· Correspondence: It may be appropriate to write to your GP or other involved professionals. Any correspondence will be discussed with you. It may be necessary for you to check such reports or letters prior to me sending them. Correspondence is either written to you as the client and copied to relevant healthcare professionals or written directly to healthcare professionals and copied to you as the client. Either way, any written letters relating to our work will be shared with you.
· Confidentiality and duty of care: All the information you share with me is confidential with the exception being if I suspect a risk of harm to you or someone else (e.g. children, partners, the general public). In this case, I would discuss any safeguarding risk with you and how we best manage it, which may include involving your GP, other care agencies or family members if appropriate and possible. Only information related to managing the risk is shared but this may be dictated by the specific information requested by the agency involved e.g. Social Services.
· Dr Rachel Seymour is not liable for any security data / security breaches that occur in external platforms / Apps e.g. WhatsApp, Signal etc.
Your Rights
You have the following rights:
· To be informed what information I hold (i.e. to be given this document)
· To see the information I have about you (free of charge for the initial request)
· To rectify any inaccurate or incomplete personal information
· To withdraw consent to me using your personal information
· To request your personal information to be erased (though I can decline whilst the information is needed for me to practice within my own professional code of ethics and conduct).
· If you wish to assert any of these rights you should contact me, Dr Rachel Seymour directly.