Policies & Privacy Notice

I have prepared this contract to offer a clear sense of what we are both agreeing to when we embark on our therapeutic journey together. I’ve tried to keep this jargon-free and focused on being clear and open with you about what we are agreeing to. If there is anything you are not sure about or you have any questions, then please let me know.

My name is Hayley Robson, and I am a Registered Counsellor with the British Association for Counselling and Psychotherapy (BACP), register number 396696. I conduct my counselling practice within the BACP ‘Ethical Framework for Counsellors’, and the BACP Guidelines for Online Counselling and Psychotherapy. Information relating to both of these documents can be found at www.bacp.co.uk

If at any point within your therapy you felt that I was in breach of these codes of ethics, I would hope that you would feel comfortable to discuss this with me and that we could find a resolution to the situation. If we were unable to do so, you could express your concerns directly to the BACP.

I am fully insured through Holistic Services Insurance.

If you have booked a session but are unable to meet at the appointed time due to unexpected or other personal commitments with less than 24 hours’ notice, I will retain the fee for that session. If more than 24 hours’ notice is given, the fee will be refunded or put towards your next session. Please let me know as soon as possible if you will be unable to attend a session, and I will do the same for you. I also ask that you give as much as notice as possible if you are due to skip a session due to holiday or another absence, and I will do the same for you.

A counselling hour is 50 minutes long and my current pricing is £55 per session or £60 for sessions from 5pm. I require payment at least 24 hours in advance. If my fee rises, you would be informed with as much notice as possible.

My aim is that you will feel comfortable enough to speak freely during our sessions and say whatever is on your mind. Apart from the following situations, I will keep whatever is said during our sessions and other contact confidential, so it will not be shared with anyone other than you:

Supervision is something that all ethical therapists attend in order to help us provide the best therapy we can for you. I may talk about our work together during my supervision, but no identifying information would be given about you. In the case of my sudden unavailability which would prevent me from contacting you, my supervisor would be able to access your contact details and notes so that they will be able to contact you and inform you of the situation. They would also be responsible for facilitating any ongoing care.

There are certain situations where I must (by law) or might break confidentiality, and they are as follows:

I must break confidentiality if:

I become aware of information which I either know or believe might help prevent another person carrying out an act of terrorism or might help in bringing a terrorist to justice in the UK, or about specified activities related to money and property used to assist terrorist activities.

If I observe physical signs that an act of female genital mutilation may have been carried out on a girl under the age of 18, or I am informed by a girl under the age of 18 that she has undergone an act of female genital mutilation.
The police request information about the driver of a vehicle at the time of an offence it must be disclosed by me as failure to do so would constitute a criminal offence on my part.
I become aware of drug trafficking or money laundering that may be required to be reported under the Drug Trafficking Act 1994, Proceeds of Crime Act 2002 or the Money Laundering Regulations 2007, if this happens, I may seek legal advice as to any statutory duty.
I must disclose information that I am ordered to by a court or by a statutory request for access to personal data made under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

I may break confidentiality if I believe that you or somebody else are at risk of serious harm, or if you have knowledge pertaining to a serious crime not yet resolved by law. A serious crime would be ‘Murder, manslaughter, rape, treason, kidnapping, child abuse or other cases where individuals have suffered serious harm or there is serious harm to the security of the state or to public order and crimes that involve substantial financial gain and loss.'

Please be aware that in order to preserve your confidentiality, if we see each other outside of the therapy room, I will not acknowledge you unless you acknowledge me first, this is simply to protect your confidentiality and boundaries.

All personal information disclosed will be kept confidential and not used for any purposes other than a counselling record. All client material is treated in complete confidence and is password protected.

If you are unsure of any of this or have any questions at any point in our therapeutic relationship, please do feel free to ask me.

In the event of an emergency arising whilst we are engaged in online work, I will discuss with you the appropriate support that you could access during this period.

Privacy Notice

I, Hayley Robson, am the Data Controller and Processor of Black Pearl Therapy.

I adhere to the code of ethics of BACP. If you are unhappy with my treatment of you, you may write to them.

The basis on which I keep client data is that of “Legitimate Interests”. This means that the data is necessary for me to fulfil the contract that we have together (i.e., to provide therapy) and that it is data that you would reasonably expect me to hold and use.

The data I hold includes:

Basic information such as name, email address, phone number
Information that you give me as part of the work we do together
Records of what interventions that I use (or potentially do not use) in our sessions
Emails, texts and/or messages that are sent between us
Information sent from any third party, e.g., GP

Some of the information that you give me may fall under the definition of special category of data as defined by the General Data Protection Regulation. The condition for processing this special data is “processing is necessary for medical diagnosis, the provision of health care or treatment pursuant to contract with a health professional”. However, data on any criminal offences (including allegations, proceedings and convictions) is even more tightly controlled and so I need your specific consent in order to hold any such information.

Data is not shared with anyone, except possibly your GP and my supervisor to ensure your continued care, and for any reasons covered by the Requirements for Disclosure section below. However, if you were to make a complaint about me to my professional body, I would be entitled to share your notes with any investigation procedures.

The data is primarily used to enable me to provide therapy for you. It may also be used scientific research purposes and statistical purposes.

Details of where data is held:

Any emails sent between us are held either on my computer’s hard drive or in OneDrive, which is secure cloud-based storage which is itself GDPR compliant.

Any data that may be held on my mobile phone is code protected.

Any texts/WhatsApp messages/Messenger messages sent between us (See Social Media and Electronic Information section) are held on my mobile phone which is code protected.

Your notes are not kept with any information about you other than either your first name or your initials.

If you use PayPal or online banking, then these systems will hold your data. I will download from these systems for accounting purposes and redact your name when uploading them to QuickBooks for my accounting.

Any recordings (only recorded with prior permission) are stored in a secure computer database on a computer which is password protected and accessible only by me.

Your data is kept for 7 years. The length of time is based on the requirements of my insurer. After this time any paper records are shredded, and computer records permanently deleted.

Black Pearl Therapy takes the security of data seriously and as such.

All data is held securely (see details of where data is held above)
Any data transmitted is sent encrypted where possible.
For accounting purposes, QuickBooks is used.

However:

I am not in control of data (including emails and texts) which you send me.

Apps such as Facebook routinely access any information held and this is beyond my control. If there is any breach of data security I, Hayley Robson of Black Pearl Therapy, will give full details to the Information Commissioners Office and any person affected within 72 hours of the breach and do all possible to minimise any potential impact.

You have rights with regards to the data held:

The right of access. I will provide you with all data I hold on you as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).

The right to rectification. If any data I hold is incorrect, just let me know and I will correct it as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).

The right to erasure. If you wish me to erase your data just let me know and I will delete any computer records and shred any paper records as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness). NB: data may be retained for scientific research, historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing, but this would never include case notes or data such as address/email/phone

The right to restrict processing. This would usually be a stop-gap measure before correction of any errors or before erasure

The right to data portability. This might apply if you want your notes sent to another therapist for example, but it is likely that the easiest solution would come under the right to access, i.e. I would send the data to you.

The right to object to:

Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling). Black Pearl Therapy does not engage in the following:

Direct marketing.
Processing for purposes of scientific/historical research and statistics. For this, you must provide grounds for your objection.
Automated decision making and profiling.

Social Media and Electronic Information Policy

This section outlines the policy of Black Pearl Therapy with regard to the use of social media and electronic information. If you, as a client, have questions about any aspect please do ask. As the world of technology is constantly changing this document is likely to be updated regularly and the latest version will always be available on my website.

Friending

I do not accept friend or contact requests from former or current clients on any social networking site as this can not only compromise your confidentiality (eg if another of my friends saw that you were a friend they may wonder how we know each other) but would also blur the boundary of the therapeutic relationship.

Following

I have a professional social media page on Facebook under the name of Black Pearl Therapy. Following or commenting on this might compromise your confidentiality. I would ask that you do not seek or follow me on any personal pages, and if I notice that you have, I would suggest we discuss this. I will not follow you on social media as this can cause confusion and blurred boundaries.

Interacting

Please do not use public ways of contact (e.g., @replies or tagging) again because of the potential for this to compromise your confidentiality. You may use Facebook messenger, WhatsApp or text to discuss appointment times or other logistics but not therapeutic issues as it cannot be kept secure.

Use of search engines

I do not routinely Google my clients but may very occasionally in a time of crisis. For example, if you had failed to attend a session and I was concerned for your safety I may try to find out about you this way. If I did so, I would tell you about it the next time we met.

Business review sites

You may find my name on business review sites, but I have not asked to be on these. Businesses do not get a choice. Clients are free to post whatever they choose and due to confidentiality, I cannot comment on anything that is posted. Indeed, anyone (including a competitor) can post anything so it is advisable to be aware that reviews (good or bad) may not be representative of the views of real clients.

It is considered unethical by some of my professional bodies (NSTT and UKCP) to publish testimonials and so you will not find any testimonials posted by me, nor will I ever ask you for one.

Location-based services

If you use location-based services on your phone you should be aware that others may surmise that you are a therapy client if you are seen as "checking in" at my address.

It is preferable to use email only for logistical contact (e.g. to get a reminder of an appointment time) due to the inherent insecurity of email.

Phone

As above, texting may be used for contact about appointment times. This is preferable to making a phone call as it is easier to respond as I cannot answer the phone if I am with another client. Email is generally preferred as I may not always have my phone to hand, and it is often on silent due to me being in sessions. Whether phoning or texting, please only do so between the hours of 10am and 6pm. You can email at any time.

Ending Therapy

You are able to end therapy at any time you wish and wherever possible I will ask that we can come to a collaborative agreement about this, however this is your choice, and I will support your right to make the decisions which are best for you. I would ask that you give notice to end our work together. This is to ensure we have sufficient time to respectfully and safely close any areas of exploration and give due attention to the ending of the therapeutic relationship.

Client’s rights

I abide by the code of ethics of the BACP and NCPS .A copy of the codes is available to you as the client, so please don’t hesitate to ask to see these.