Jo Robinson-Castro
Privacy Policy
This privacy notice explains how I will manage your personal information, including why I collect it, how I use it and how I keep it secure. I am registered with the Information Commissioner’s Office (ICO), and I adhere to current data protection legislation. My ICO registration number is ZB777183.
Contact Details:
Email - hello@jorobinsoncastro.co.uk
Telephone - 07828 482483
Information I Collect & Use
To provide you with the best possible counselling service I will collect your personal contact details, including your name, address, phone number and email. I will also request your pronoun preferences, your date of birth, emergency contact details, GP details, some health information (including medical conditions, allergies, and any medical requirements relevant to an emergency). These personal details are necessary to arrange our work together and to support you in the case of an emergency. I will only collect information directly from you.
I keep brief, factual notes about our sessions. These are used as an aide-memoire for me. I will also keep a record of sessions scheduled, attended and fees paid, which are needed for fulfilling my tax obligations.
Information Storage
I store your personal information in a way to minimize the risk of unauthorized access or breaches of confidentiality. Information held electronically is stored on a password protected computer. Information held in physical paper form, such as a signed copy of our counselling agreement, is stored in a locked filing cabinet. Any communications between us via email or text and accessed on my phone are password protected.
Data Retention / Deletion
If you become a client, I will keep your personal information for the duration of our work together and five years thereafter. This is in accordance with the recommendation made by my insurance company. If you make an enquiry via my website or a counselling directory, I will keep your basic contact details for not more than 6 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.
Data Sharing
Our work together is confidential. However, there are limited situations in which I may need to share your relevant personal information, as follows:
GP, other health providers or emergency services - if I have a major concern and need to safeguard yourself or others from serious harm, I may need to contact your GP or another health service. I would aim to discuss this with you in advance to gain your consent, but in an emergency this may not be possible.
Supervision – to maintain high standards of professional practice and meet the obligations of my professional bodies, I engage in regular clinical supervision. Only your first name will be used, and my supervisor is bound by the same codes of confidentiality as I am and is UKCP or BACP registered.
Clinical will – in the event of my death, serious illness or other incapacitation that prevents me contacting you personally, I have appointed an executor of my clinical will. This is a requirement of my professional associations. The executor is a trusted colleague who is also UKCP or BACP registered and is authorized by me to communicate with you in these circumstances. This person has access to your name and contact details to inform you of my inability to work and to support you in planning for ongoing support if you wish.
Legal obligation – I may have to disclose some personal information if required to do so by a court of law.
Lawful Bases & Your Rights
Under UK data protection Law, I must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR, which you can find out more about on the ICO’s website.
My lawful bases for collecting or using personal information to provide counselling services are those of consent and contract:
Consent - I have permission from you after I gave you all the relevant information. All your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – I must collect or use the information so I can enter into and carry out a contract with you. All your data protection rights may apply except the right to object.
You have the right to ask me for a copy of the personal information I hold for you, which is called a ‘Subject Access Request’. I will provide this information to you within 30 days. You have the right to ask me to correct or delete personal information you think is inaccurate or incomplete. You also have the right to ask me to delete your personal information. Please make any request in writing to [email protected] and I will endeavour to do so unless I am required to keep information for legal or internal business purposes.
How to Complain
If you have any concerns about my use of your personal data, you can make a complaint by contacting me at [email protected]. If you remain unhappy with how I’ve used your data after raising a complaint with me directly, you can also complain to the ICO. For more information visit the ICO website.
Privacy policy last updated: 11th October 2024