I take your privacy seriously and I am fully committed to ensuring that your privacy is protected. I hope this policy is everything you need to know about how I use and protect any information that you give me. 

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Third party privacy statement 

From the moment you get in touch with me I will not try to obtain information about you from any third party without your knowledge and consent.

Nor will I share your information with any third party - unless you have explicitly told me that you would like me to do so.

There are, however, three lawful exceptions to the above.

These exceptions apply when:

•  there is an issue relating to child protection

• where a court order has been issued

• or where there is significant risk to yourself or others.

​​I explain this in greater detail under 'Legal exceptions to obtaining your consent' below. 

Supervision

I may have supervision with another specialist practitioner as part of my ongoing professional development. Your information may be shared with the supervisor who is also professionally bound with respect to issues of confidentiality.

The lawful basis for processing your data

I only use information about you in ways that are legally and ethically essential for me to fulfil my role as an effective, safe and responsive professional to you. 

Newsletters and marketing campaigns

I do send newsletters and marketing campaigns and you may be included in these. You are welcome to unsubscribe from these data bases at any time. You will find an unsubscribe button​ at the foot of each relevant email.

Disclaimer: Your role in protecting your own privacy

I make every effort to ensure that my clients' personal information is held securely, and to safeguard against unauthorised access, whether I receive it via my website, emails, text, over Zoom or phone, or in person. At the same time, in agreeing to my privacy policy,

1. You acknowledge that the privacy of your communications and personal information can never be completely guaranteed when it is being transmitted over the internet. 

2. You therefore acknowledge and agree that you share information via the internet at your own risk.

3. You agree to take responsibility for your own role in safeguarding your data privacy in the email address you choose to use and whether or not you choose to password protect information you send to me. 

That having been said, I have never had an instance of any of my client's information being leaked over the internet.​

How do I obtain information about you?

I obtain information through:

• whatever you choose to share with me [via any online forms that you fill in, via email (and attached documents) and via any other communications we may have - over the phone (text or voice message), via online applications (such as  Zoom) or in face to face sessions].

• your healthcare provider or other professional, if relevant, and with your consent

• any person making initial enquiries or referrals. 

If we agree to work together, I will of course want to get to know you, your needs and aims and life context. I will need all relevant information so we can work well together. 
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My website's contact and informed consent forms and the Acuity booking system

​If you get in touch via my contact or informed consent forms or via an Acuity booking, the information you provide goes through to me via email. 

About your initial free consultation

​If you make initial contact with me over the phone, or choose a free exploratory consultation, I will typically ask for some sensitive information at that stage of our contact.
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Your privacy 

Emailing each other 

​Once we've agreed to work together, I'll ask you for an email address and a phone number. Emails from me identify me as a professional so please choose an email address with this in mind!

Online sessions 

​Zoom services have updated their privacy measures to ensure they are fully compliant with GDPR regulations 2018.   
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Obtaining information from third parties 

​Occasionally I get enquiries from referring professionals, from client's family members or from concerned others making initial enquiries that share sensitive information because they want to help. If this is the case for you, I will let you know that this has happened when we first meet and I look forward to hearing and exploring your own point of view.

Further contact with referring professionals, with your family members or with concerned others will only be with your consent unless there is a legal issue which obliges me to contact them or if there is significant risk to yourself or to others (see 'Legal exceptions to obtaining your consent' below). ​

On occasion, with your prior knowledge and consent, I may ask for information from other healthcare providers involved in your care, for example if you are working with a psychologist, psychiatrist or another therapist. This will only be to ensure I am taking the most appropriate, safe, responsive and effective approach to our work. Again, this will only be with your consent unless there is a legal issue which obliges me to contact them or if there is significant risk to yourself or to others. ​

If you're working with another healthcare provider, such as a psychiatrist or psychologist, you or they may wish for me to have information about you. I will only receive information from them if I have your consent unless there is a legal issue or if there is significant risk to yourself or to others.​ 

What type of information do I collect about you? 

​I will collect personal information from you if we decide to work together.

This information is usually collected via a form entitled: "Informed Consent." 

You can view that form here.

Personal Information includes

• Your name, your occupation, your address, your contact details, the name of the person who referred you and your date of birth.​ 
  
  

Sensitive Information 

​Given the nature of healthcare related data, some of the information you may share with me is likely to be classified as sensitive. I'm legally required to take strong measures to protect your confidentiality with any of the following sensitive information that would be important for me to know in order to help you:

• Your mental and physical health

• Use of alcohol, prescribed and non prescribed drug use

• Any criminal offences or alleged offences                              

If you choose to share any information with me about your relationship or sexual history or orientation, your family, lifestyle, employment, religion or cultural background, this is also respected as 'sensitive information'.                        ​

What do I use your information for?

I may at times need ask you about some of the above sensitive information with the specific purposes of ensuring that:

• the service I provide to you is properly responsive to your specific circumstances and needs. 

• I make safe and effective professional decisions 

• I respond to you in the most considerate way

• we communicate openly with one another to make wise and appropriate decisions together in a teamwork approach 
   

With regards personal and sensitive information, I don't need to have a written record of everything you share with me! In fact, I keep my own note taking in session to a strict minimum, in order to stay fully present, attentive and connected to you, as these are far more important aspects of transformative teamwork than writing notes!

I keep my note taking outside of sessions to a minimum too, and, instead encourage my clients to keep their own notes of useful ideas, insights and reflections. As they relate to you and your progress, it's much more relevant and helpful that notes are written by you and stay in your possession!

There are of course some things that I must, legally, have a written record of, if it is in direct relation to your safety or the safety others, such as emergency contact information, or information related to suicide risk, child protection, domestic abuse, or other violent crime, or should I ever need to account for my professional decisions and/or respond to complaints. 
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Stored records

Stored records comprise of:

• the emails, reports, questionnaires, forms or letters you have decided to send or ccd to me

• emails, reports, questionnaires, forms or letters I have sent or ccd to you to the email address of your choice

• any information you have forwarded to me from a healthcare provider or insurance company

• any information that I have received from a healthcare provider (I will always show you if you have not already been ccd)

• any information I send to an insurance company or healthcare provider (I will make sure you have a chance to read and rectify as appropriate before I send)

• and, if a legal or risk issue has been identified: risk assessment and risk management plan, and my supervisor's recommendations, which I will also share with you, unless it would increase a safety risk to do so.

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Measures I take to store your data securely

These are the measures I take to protect your data:


Storing paper information securely 
I keep handwritten or printed information about you or our teamwork to an absolute minimum in order to protect your data. 

​I do not print or keep duplicate information wherever this can be prevented. For example, if you or your general practitioner have sent me digital information via email, I do not then print it. 

All handwritten or printed information that has any personally identifying information on it about my clients is kept in a securely locked room. 

Keeping electronic information securely stored  

My devices are all password protected, with strong passwords which I change at suitable intervals. I do not share my devices or passwords with anyone else.​ 

I do sometimes record phone or Zoom sessions for the purposes of supervision. 

I clear my downloads related to client information on all devices when I am not actively making use of those downloads.  

I do keep your personal or sensitive information stored on an external hard drive. This is stored in a locked room. 

All Apple and Google services are GDPR compliant with regards level of security and privacy protection.
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Who I may need to share your information with?

Third parties

​If I am obliged legally to share information or if there is risk of harm to yourself or to others, I may share that information without your permission (see below under 'Legal exceptions to obtaining your consent'). 

In all other circumstances:

I will always ask you for your consent before sharing any personal or sensitive information when liaising with other health professionals who may be involved in your care. 

I will always ask you for your consent before making appropriate referrals to other healthcare providers.

I only share sensitive information that would be of direct importance to your healthcare ie directly relevant to you getting the most appropriate treatment for your needs. ​​

Legal exceptions to obtaining your consent 

There are three situations where I would be legally required to share your information with third parties, without your consent:

• Court Order
  If I am required to disclose data about you, under a Court Order for me to do so.

• Child Protection
  If I am concerned about the welfare of a child, i.e., where there are child protection issues relating to potential physical, mental, sexual abuse or serious neglect

• Risk to self or others            

Where there is an imminent risk of serious harm to yourself or harm or exploitation of others. 

That means, for example that - if you're seeking help and you are perpetrating a serious crime against someone - I am unable to protect your right to privacy as I must legally take appropriate action to protect the safety of children and vulnerable adults, if I believe they, or you, are at risk of harm. ​Similarly, if you are actively suicidal, I would not necessarily protect your right to privacy.

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Contacting me if you have any questions

If you have any questions or concerns about how your data is processed or shared, please do not hesitate to contact me by emailing jeremy (at) jeremydetolly.com