Privacy policy
James Bolton Therapy privacy notice
This privacy notice tells you what to expect us to do with your personal information.
Contact details
Telephone
07343014920
James Bolton, trading as James Bolton Therapy, is the data controller responsible for the personal information described in this notice.
What information we collect, use, and why
We may collect or use the following information to provide counselling and therapy:
Name, address and contact details
Gender
Pronoun preferences
Date of birth
Next of Kin details including any support networks
Emergency contact details
Health information (including medical conditions, allergies, medical requirements and medical history)
Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)
Payment details (including card or bank information for transfers and direct debits)
Records of meetings and decisions
GP details, contracts and consent records, risk and safeguarding information, correspondence, attendance and appointment records.
We may also collect the following special category information to provide counselling and therapy. This information is subject to additional protection due to its sensitive nature:
Racial or ethnic origin
Religious or philosophical beliefs
Health information
Sex life information
Sexual orientation information
We collect or use the following personal information for dealing with queries, complaints or claims:
Names and contact details
Addresses
Payment details
Customer or client accounts and records
Financial transaction information
Information relating to health and safety (including incident investigation details and reports and accident book records)
Correspondence
Therapy agreements, clinical records relevant to the complaint, risk and safeguarding records, complaint investigation notes, and correspondence with supervisors, insurers, professional bodies or legal advisers.
We may also collect the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:
Racial or ethnic origin
Political opinions
Religious or philosophical beliefs
Health information
Sex life information
Sexual orientation information
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide counselling and therapy:
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legitimate interests - we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
I have a legitimate interest in collecting and using proportionate personal information where this is necessary to provide safe, appropriate and professionally accountable counselling to children and young people, particularly where the young person is not themselves the contracting party or where their capacity to enter into a contract may be uncertain. This processing supports the child or young person’s access to therapy, continuity of care, appropriate assessment, risk management, safeguarding and clinical supervision. It may also involve using limited information provided by a parent or carer where this is necessary to arrange and safely provide the service. I consider the child or young person’s best interests, rights and reasonable expectations before using their information. I collect only information that is relevant and necessary, explain its use in age-appropriate language, restrict access, use anonymised information in supervision wherever practicable, maintain clear confidentiality boundaries with parents and carers, store information securely and retain it only for defined periods. These safeguards reduce the potential impact on the child or young person’s privacy and ensure that my interests do not override their rights and freedoms.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
I have a legitimate interest in using relevant personal information to respond to enquiries, investigate and resolve complaints fairly, maintain accurate records of decisions and correspondence, and establish, exercise or defend legal or professional claims. This processing is necessary so that I can understand the issue raised, verify what occurred, respond appropriately, obtain advice from my supervisor, insurer, professional body or legal adviser where required, and demonstrate that I have acted safely and professionally. I use only information that is relevant to the particular enquiry, complaint or claim, restrict access to those who genuinely need it, store it securely and retain it only for an appropriate period. Where the information concerns a child or young person, I give particular weight to their rights, welfare and reasonable expectations. I consider that these safeguards mean my legitimate interests do not override the rights and freedoms of the people involved.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Where we get personal information from
Directly from you
Family members or carers
Other health and care providers
Charities or voluntary sector organisations
Schools, colleges, universities or other education organisations
clinical supervisors, referral partners and emergency or safeguarding services where relevant.
How long we keep information
We will keep your information for 7 years from the end of our working together.
For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
Who we share information with
Data processors
Google LLC
This data processor does the following activities for us: I use Google services, including Gmail and, where applicable, Google Drive, Google Calendar and Google Meet, to manage client enquiries and correspondence, store administrative documents, arrange appointments and conduct online meetings. Information processed through these services may include names, contact details, appointment information, correspondence and documents sent to or received from clients. I limit the information used through these services to what is necessary for providing and administering the counselling service.
Others we share personal information with
Other health providers (eg GPs and consultants)
Insurance companies, brokers and other intermediaries
Organisations we need to share information with for safeguarding reasons
Emergency services
Professional advisors
Local authorities or councils
Organisations we’re legally obliged to share personal information with
Other relevant third parties:
Parents, carers or people with parental responsibility, where sharing is appropriate and lawful.
Duty of confidentiality
We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:
you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
we have a legal requirement (including court orders) to collect, share or use the data;
on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
The requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied
Sharing information outside the UK
Where necessary, we will transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.
For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.
Organisation name: Google LLC
How to complain
If you have any concerns about our use of your personal information, you can make a data protection complaint to us:
jamesboltontherapy@gmail.com
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint