EU General Data Protection Regulations 2018

From May 2018, the storage and use of personal data and special category data (previously called ‘sensitive’ data) is covered by GDPR instead of the Data Protection Act, where data is held electronically or where written files are stored in an organised filing system. Although this does not apply to the great majority of the data kept by The Harley Consultancy, we are registered as a Data Controller with the Information Commissioner’s Office and have complied with these requirements. This means that you need to understand what data is being stored and how it will be used.

  1. The basic personal details contained on the Client Details form are stored for the purpose of:
  • complying with our obligations under our contract for psychotherapy
  • managing arrangements for sessions
  • obtaining payment (such as from health insurers or other third-party funders, where relevant)

This form is securely destroyed 12 months after we have finished working together.
Lawful basis under GDPR: Contract        Separate consent not required

 

  1. Brief details of matters discussed during sessions are stored for the purpose of:
  • complying with our obligations under our contract for psychotherapy
  • managing the therapeutic process
  • liaison with relevant third parties (including but not limited to supervisory consultation, health insurers or other third-party funders, and requesting further sessions), where relevant.

These notes are securely destroyed 12 months after we have finished working together.
Lawful basis under GDPR: Contract         Separate consent not required

 

  1. In exceptional circumstances, where risk of harm to self or others is considered to be present, or the law requires, essential details may need to be shared with medical or statutory departments for the purpose of managing this risk or complying with the law. Specific consent for this will always be sought first, where it is possible and practical to do so.
    Lawful basis under GDPR: Legitimate Interests     Consent will be sought, where possible 
  2. Your name and email address will be stored on The Harley Consultancy’s mailing list for the purpose of:
  • keeping you up to date with news, relevant information, offers and events (including but not limited to receiving the occasional Harley Consultancy newsletter).

You are able to unsubscribe at any time.
Lawful basis under GDPR: Legitimate Interests       I would like to opt in: please initial

5. Under the provisions of GDPR, you have the right to make reasonable requests in writing:

  • For your personal data to be erased or to no longer be processed
  • For your personal data to be provided in a machine readable format for use in an alternative service. There is no cost for this.
  • For sight of the personal data being held on you. The data will be provided within one month. There is no cost for this. If you believe there is an inaccuracy in the records you can request that they are amended, or add a note of any objections to your records.