Senta Sharp Counselling - Privacy Policy

last updated 31/03/20

Who does this Privacy Policy apply to?

 

This privacy policy explains how Senta Sharp Counselling uses and protects any information that you give to the Practice, such as a client, agent, health professional, someone who visits the website. The Principal, Senta Sharp is responsible for controlling data protection in relation to her services and practices, complying with the Privacy Act 1988 (AU) and General Data Protection Regulation (GDPR) (EU) 2016/679 for any international work in the EU and UK.

 

Any other practitioner who is contracted or employed by Senta Sharp Counselling and who collects information on behalf of the Practice is also bound by this privacy policy and required to comply with the International regulations and/or national legislation of the country or region they are working in.

 

Consent

 

Any information you provide will only be used in accordance with this privacy policy. If you are engaged in therapy, you will be notified of any changes made to this policy.  

 

When you engage Senta Sharp Counselling, you will be provided with this Privacy Policy and asked to agree that you understand how this Practice handles your information. By engaging Senta Sharp Counselling, you will be consenting to the way this Practice collects, stores, and handles your health information.  

 

By engaging in services with www.sentasharpcounselling.com you are accepting and consenting to the practices described in this policy.

 

 

What information is collected and when is it collected?

 

Senta Sharp Counselling collects two main types of information:

 

  • Personal health information and
     

  • Information technology information.

 

Personal Health Information

 

Personal health information is collected from client intake forms when you first engage counselling services, during sessions, and from other sources if applicable, to provide you with health services.

 

The Practice uses electronic forms that you will be asked to complete with details that can identify you, such as

 

  • Name, date-of-birth, your physical and mailing address, email address and phone number, and a nominated support person, next-of-kin and/or guardian.
     

  • General Practitioner or other allied health professional contact details.
     

  • The details of any support agency involved with a client, when appropriate.
     

  • Information required for invoicing purposes, such as insurance details, if applicable.
     

Other Information may be collected when you engage Senta Sharp Counselling, during therapy sessions or email exchanges about your physical or mental health, notes about your symptoms, records of fitness, gender, race, sexuality, religion, doctor’s reports, referral letters, family history, appointment and billing details.

 

All information that is collected from a client, explicitly or implicitly, obtained from a third party professional services provider, or acquired by a counsellor during a session making a record of what you say, or the counsellor’s opinion of what a client says, for inclusion in a file or record, is regarded as health information, and deemed to be “sensitive information” and will be handled securely under the guidelines of The Privacy Act.

 

Information Technology Information

On visiting the website, www.sentasharpcounselling.com information may be automatically collected:

  • Technical information, including the Internet Protocol (IP) address used to connect your computer to the internet.
     

  • Information about your visit to the website, e.g. date and time, pages visited. Your identity will not be collected from this information.
     

This information may be collected using cookies. Cookies are small files of letters and numbers that the website or service provider stores on your browser or your computer’s hard drive (if you agree).

Senta Sharp Counselling uses this information to assess which pages are most frequently visited and to help improve the site with easy access, and useful and relevant information.


Where is information collected from?

Senta Sharp Counselling only collects personal information that is reasonably necessary to provide you with counselling services. This information will be primarily collected directly from you. 

 

In an emergency, I may need to collect additional health information from your nominated support/contact person.

 

When a client is a minor, or an adult who lacks capacity, I may need to collect information from parents, guardians or relatives who have been nominated in the contract for services.

 

Information may also be collected from other sources, depending on the nature of the service being provided and the therapeutic work, such as:


• From insurers/solicitors if fees are being paid through insurance arrangements.

• From a GP or other health care professional, where appropriate.

• From professional regulatory bodies.

• From publicly available material.

 

At all times, I will endeavour to collect information in an honest, fair and non-intrusive way. Any other information not listed here will only be collected using lawful and ethical means.

 

Senta Sharp Counselling does not:

 

  • store bank account or credit card details.
     

  • record or monitor calls. If a call or video session was to be recorded, you would be informed at the beginning of the conversation to seek your permission, complying with the Telecommunications (Interception) Act 1979 (Commonwealth).

 

Why do we need to collect your personal information or data?

 

Senta Sharp Counselling has a legal basis for collecting your personal information. 

 

  • I have a legitimate interest in collecting personal health information from you. It enables me to communicate in a personal way, and with honesty and trust, to provide counselling for your health and well being. 
     

  • I have a legal contract with you to provide services and process your payments for those services.
     

  • I have a legitimate interest in providing you with a useful and relevant website, optimising your experience wherever possible.

 

 

How is your information used?

 

Your information will be used in the following ways:

  • To perform business activities related to providing online therapy services (e.g. making appointments, delivering therapy, notifying you of changes, recording invoices, and tax records).
     

  • Your name and contact details will be part of a client database, and I will use these details to liaise with you.
     

  • Your therapeutic file is held privately and only accessed by the counsellor you have an agreement with to provide therapy. As part of ethical requirements, a registered counsellor is required to have formal supervision and present aspects of some therapeutic cases. Your identity and any aspects of your situation that could identify you will remain private and will not be revealed in supervision.
     

  • In the event of a serious illness or injury to your counsellor, the supervisor will have access to your contact details only (not your therapy file), in order to inform you and discuss alternative therapeutic arrangements with you.
     

  • For you to use website features to provide your contact details and/or make an enquiry.
     

  • For payments via PayPal or Direct Debit transfers your name and email address will be used.
     

  • For the purposes of regulatory or legal proceedings.
     

  • If as your counsellor I believe there is a reasonable risk of harm, to safeguard against that harm.
     

 

How is your information stored and protected?

  • Senta Sharp Counselling uses an end-to-end encrypted email server, ProtonMail, for secure transmission and storage of emails.
     

  • Personal information collected through the website is secured using Hyper Text Transfer Protocols (HTTPS) and Transport Layer Security (TLS). The site is secured using a Secure Sockets Layer (SSL) Certificate to protect all data.

 

  • All information collected from you is filed electronically using an Advanced Encryption Standard cloud storage.  

 

  • The electronic files with your personal identifying details are stored separately from your therapeutic file to add another layer of security in the event of compromised files.
     

  • It is not possible to guarantee that the transmission of information via the internet is 100% secure, however Senta Sharp Counselling takes all available steps to check and regularly review the integrity of security systems to maintain the security of your data.
     

  • Any health information obtained as part of therapy that is stored on local computer drives is protected with strong passwords and does not include any personally identifiable information.
     

  • Paper notes and back-up hard drives are held in a locked secure space.

 

 

How long is your information kept?

 

All personal information about you, including your record/file, contact details, and any communication between you and Senta Sharp Counselling is stored for 7 years.

After this time, unless you are an ongoing client continuing to have therapy, your information will be deleted securely and permanently, in both hard copy and electronically, unless there is a legitimate reason for retaining your personal information, such as:

  • A legal obligation requires the information to be held
     

  • A client has a risk to their safety which provides a duty-of-care for a health professional and a need to safeguard the individual
     

  • A professional or ethical obligation requires reporting to a professional organisation
     

  • possible regulatory or legal proceedings

 

 

Is your information shared with outside parties?

 

Your information will never be sold, traded, or transferred to a third party by this Practice.

Depending on your individual circumstances, and only when appropriate, information may be shared for specific reasons, with the following people:

  • A GP or other health care professional in connection with therapy, in addition to any relevant agency when there are safeguarding concerns or a need to refer you to their services.
     

  • The Counsellor’s Supervisor for the purposes of meeting professional requirements for regular supervision. Your information will be de-identified to ensure your privacy is not compromised. In the event of the counsellor’s death or circumstances preventing ongoing practice, your contact details only will be provided, in order to inform you of the circumstances and help you to find alternative arrangements for therapy.
     

  • Third party professional service providers, such as accountants or solicitors for invoicing, payments, taxation, and the proper management of the practice.
     

  • Relevant organisations where there are safeguarding concerns with respect to any individual.
     

  • The relevant professional regulator where it is necessary to report potential breaches of ethical principles, codes of professional conduct, or a breach of data occurs.
     

  • Relevant bodies or organisations to whom the Practice is legally obliged to inform.
     

  • Your information may need to be shared with overseas authoritative bodies such as AOIC (AU) or OIC (UK) if you are receiving counselling from a counsellor in another country associated with this Practice.

 


How can you access, amend, or delete the information held about you?

You can request access to the personal information that is held about you.  You may also ask for your personal information to be amended if it is inaccurate or out-of-date, or to be deleted.  Some information does need to be retained by the Practice for legal and business reasons (e.g. for tax purposes).

 

Any requests will be discussed with you personally. Requests and changes made are free, and information will be provided in a format that is acceptable to you, in electronic or hard copy versions.

 

For any requests to access or change/delete the information we hold about you, please contact Senta Sharp, info@sentasharp.com.au

 

Questions, comments, and complaints

 

If you have any questions or comments about your privacy with Senta Sharp Counselling, or if you would like to change or access your personal information, please contact the Principal, Senta Sharp at info@sentasharp.com.au  or write to Suite 13, 1b/47 Park Rd, Milton, QLD 4064 Australia.

 

The Practice only collects and keeps information about you with your written consent, and complies with the National Privacy Act 1988, Australia.

 

I regularly review my practices and the integrity of privacy procedures and therefore welcome your feedback about how information is collected and handled.

 

If you have a complaint, please bring it to the Principal’s attention by phone or email. Your complaint will be investigated, and you may be contacted by phone or email in the first instance, with written information about the progress and outcome of your complaint.  

 

If you make a complaint which has not been addressed or is not resolved to your satisfaction within 30 days, in Australia you can contact the Office of the Australian Information Commissioner on https://www.oaic.gov.au/privacy/privacy-complaints/ or in the UK, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/handling/

 

 

Changes to the Privacy Policy

 

If there are any changes to the privacy policy, the Privacy Policy will be updated and the date it was modified will be indicated on this document. The current Privacy Policy is available on the website www.sentasharpcounselling.com. If you are a current client of the Practice you will be advised if there have been changes to the Privacy Policy.

© 2020 Senta Sharp.

SENTA SHARP COUNSELLING SERVICES

Senta Sharp Psychotherapist & Counsellor

sentasharpcounselling.com