Background
In order to provide you with the best service possible we need to hold your personal contact details and, in some cases, the records of your therapy sessions. This privacy notice tells you what we will do with your personal information from initial point of contact through to after therapy has ended. Your privacy is very important to us and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to The Farley. We adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR) and the United Kingdom's retained version of the GDPR as implemented by the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
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We also adhere to the ethical guidelines regarding protecting client privacy and confidentiality set by the British Association for Counselling and Psychotherapy (BACP).

When you contact The Farley through our enquiry form or via email, you give us consent to store your personal information in order to provide our services to you. Please read this Privacy Policy carefully so that you understand how I handle your data.

Lawful basis for holding and using your personal information
The GDPR states that we must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which we are processing your data. If you have had therapy with Esther Dietrichsen-Farley, and it has now ended, she will use legitimate interest as her lawful basis for holding and using your personal information. If you are currently having therapy with Esther Dietrichsen-Farley, or if you are in contact with The Farley to consider therapy, we will process your personal data where it is necessary for the performance of our contract. The GDPR also makes sure that we look after any sensitive personal information that you may disclose to The Farley appropriately. This type of information is called ‘special category personal information’. The lawful basis for us processing any special categories of personal information is that it is for provision of health treatment (in this case therapy sessions) and necessary for a contract with a health professional (in this case, a contract between you and The Farley).

The Farley will retain your name, your email address, your phone number and the dates when you entered and finished therapy on our system for up to two years of the date when you finished therapy.

Information we record
The information we request from you may include personal information, such as your full name, your phone number, your email address, your GP details, and your date of birth. We may also ask for sensitive personal information, such as ethnicity, gender sexuality, marital status, sexuality, offences, the status of your physical and mental health or religion and beliefs.

If you are currently having therapy with Esther Dietrichsen-Farley, The Farley will also hold information such as anonymised therapy session notes, anonymised risk assessments and safety plans. 

How we use your information
The Farley will never use your personal data for any purposes other than the administration of the therapy service provided to you i.e. to arrange, cancel and rearrange appointments. We will only retain your personal information for as long as it is necessary. This is in line with guidance from the Information Commissioner’s Office.

The personal information we collect about those who use our services is used to provide the services requested and to operate our business efficiently. We use it for billing, identification, authentication, service improvement, research, and for contacting you when necessary.
 
After therapy has ended: There are reasons why we might be required to keep records after your therapy has ended. For example, in the case of financial transactions personal information must be retained for as long as legally required in respect of tax or accounting purposes. In case of therapy with Esther Dietrichsen-Farley, retaining your therapy notes ensures that we can continue to offer you an efficient service if you make contact after therapy has ended. Your therapy notes do not include any personal details that could be used to identify you and continue to be stored securely on our password-protected computer equipment for two years after your therapy has ended. Two years after therapy has ended your therapy notes will be confidentially destroyed.

Your personal details form is confidentially destroyed on ending of your therapy sessions. Please note that we need to keep a record of your name, date of birth, email address and your client reference number for two years after your therapy has ended. Your client reference number corresponds with a client reference number on your therapy notes and therefore enables us to identify your therapy notes if necessary.
 
Third party recipients of personal data
We share a limited amount of personal data with third parties in order to provide our services to you and to fulfil legal obligations in respect of tax and accounting purposes. For example, our accountant is permitted access to my invoices. We will never pass on your contact details to any third-party organisations for the purposes of sales, marketing or research.
 
Data security
We take the security of the data that we hold about you very seriously. Our email account is password protected and mobile phones and laptops used to respond to your emails are password protected and have anti-virus software. Any email correspondence will be deleted within six months if it is not necessary to keep it.
 
Information Sharing
We may disclose personal information when we believe it violates our Terms of Service, when it is required to assist with a lawful investigation or comply with the law, if we believe disclosure is necessary to protect our rights, or if some or all of the assets and operations of our business are or may be transferred to another party.

If we believe that you or others might be at risk of harm, we reserve the right to share your personal information without your consent with either Police Service, Ambulance Service, Fire Service or Social Services.

We will not sell, rent or share your personal information with third parties in other ways without your consent unless we are entitled by law to do so.

Website visitors
By accessing the website, you are consenting to the information collection and use practices described in this privacy notice. Should you choose to contact me using the enquiry form on the website none of the data that you supply will be stored by the website or passed to any third-party data processors. Instead, the data will be collated into an email and sent to me over the Simple Mail Transfer Protocol (SMTP). SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted before being sent across the internet. The email content is then decrypted by local computers and devices.

The website uses cookies and Google Analytics. Almost all websites use cookies which are small files that get put on your computer by websites as you surf them. These cookies can store lots of information which can have privacy implications. Google Analytics is a service provided by Google that gathers anonymous data on how people are using websites and then provides visitor statistics, details of page views, etc. This service is used by many website owners as the data helps website owners to improve their websites. If you wish to change your cookie settings then you may do so through most browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them visit www.aboutcookies.org or www.allaboutcookies.org.

In many cases the cookies are used to generate identical information to Google Analytics and indeed use Google Analytics, so opting-out of Google Analytics will also opt you out of these cookies too. You can opt out of Google analytics and other Google services here – http://tools.google.com/dlpage/gaoptout and https://www.google.com/dashboard/.

When you email us
The Farley uses Google Mail to supply our email service, and Wix to host our website including the online enquiry forms on our website. Both companies are required to be complaint in protecting your data.

We also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

Your rights
Under GDPR, 2018 guidelines you have the following rights: The right to request access to the personal information that we store and process about you. You can ask for corrections to be made to the information held or for your personal information to be deleted. You can also ask me to restrict the processing of your personal information or to object to the processing of it altogether in some circumstances. You can read more about your rights at ico.org.uk/your-data-matters. If you would like to make a request relating to any of the rights above, please send a request in writing by emailing to esther@thefarley.co.uk. Please be aware that in certain situations counsellors may be unable to comply with the above requests. For example, if compelled to retain the records by a court of law. Please also be aware that there may be a charge for complying with a request if it is deemed to be excessive in nature.

Queries
‘Data controller’ is the term used to describe the person or organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is Esther Dietrichsen-Farley and she is registered with the Information Commissioner’s Office. If you have any questions about this privacy policy or the way in which we handle your personal information you can contact her via email at esther@thefarley.co.uk.

Access and Correction
You can request access to personal information we hold about you. We will provide this except in the limited circumstances in which we are permitted not to.

You may request that I correct personal information I hold about you that is inaccurate or out-of-date. If you request that I delete your personal information, I will take all reasonable steps to do so unless I need to keep it for legal purposes or for other exemptions to the right to erasure in GDPR Article 17(3).

Complaints
If you have a complaint about how we handle your personal data, please do not hesitate to get in touch by email to esther@thefarley.co.uk. If you want to make a formal complaint about the way we have processed your personal information you can contact the ICO which is the statutory body that oversees data protection law in the UK. The data controller is Esther Dietrichsen-Farley and she is registered with the Information Commissioner’s Office: the registration number for Mrs Esther Dietrichsen-Farley is ZB661500. For more information go to ico.org.uk/make-a-complaint.
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Changes to privacy notice
This privacy notice may be updated from time to time, so please check occasionally for any updates.