Haven Counselling and Coaching

GDPR Data Protection and Privacy Policy (Renewed 9th April 2019)

Our contact details:

Mr. Rob Stroud (Data Controller and Processor)

Haven Counselling, Hill Head Road, Fareham, Hampshire, PO143JL, England

Email: havencounsellor@protonmail.com Phone: 01329 661926 Web: www.havencounselling.co.uk


We collect and hold the following information:

• your contact details including name, email address, phone numbers and address and booking details

• financial information: such as invoices, payment record / receipt and payment method (we may generate invoices using secure online platforms (see below).

• your next of kin to contact in emergency (optional) and your General Practitioner’s / Mental Health practitioner’s contact details

• website user stats (analytics)

• Therapy information: notes on sessions, data you give in from enquiry forms or psychological assessments, any other material you consent to give me to hold for the purposes of our work together


How we get the information and why we do we have it:

ENQUIRIES and BOOKING: We collect information either from enquiries you make either online via our website www.havencounselling.co.uk, over the phone or in direct consultation in person. If you use our booking platform (currently 10to8) and you agree to complete information about why you are seeking counselling or coaching and any particular needs you have, this information will be retained for the purposes of helping us provide you with a safe and effective service. The same applies for any other platform through which you provide information. We have checked the security and encryption of this platform.

BASIS: We collect the above information on the legal basis of ‘Legitimate interests’ which means the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. It is important we process and retain data about your personal identity for your safety; to ensure efficient processing of payment and to ensure we can keep track of your progress/ wellbeing. We are also required to retain data for insurance purposes.

CLINICAL BENEFIT: Your personal data will be used to help keep track of your therapy / coaching in order to maximise the benefit to you and minimise risk to you. It will be shared with my clinical supervisor (see below for how this is done). The data may be required in the event of a complaint taken to our professional body or in the event of any legal dealings in a claim via our insurers or if we are required to share it by Court of Law.

NOTE THAT: Your data may pass outside of EU or UK servers if you send data via a Google Enquiry form (on the website) or via another platform such as Facebook pages. 10to8’s server is highly secure and based in Ireland and therefore remains within the EU.

Your basic contact details as well as appointment time will be used if you consent to have SMS text reminders or emails via the booking platform 10to8. Likewise, in order to contact you for a particular purpose (eg invoicing or in response to an enquiry), your data will be used at the minimum level required but we do ask you to inform us if you do not wish to be contacted via a particular means.

FINANCIAL: Invoices may be generated using a secure online platform (e.g. Wave) to facilitate payment for your convenience. These can be sent to you electronically if you wish (e.g. via email) but will normally be given directly to you in session. Pseudonymns are used instead of your name on invoices but if you wish to pay online, your financial transaction (e.g. bank transfer or card payment) will be logged by the platform. If you do not wish payments to be logged in this way alternative means of invoicing and payment are available on request.


How we store your information:

Your personal data (identifying information like name and contact information) is held securely and separately on encrypted, password-secured electronic storage only accessible by Rob Stroud at the business address (above) backed up to the cloud . Session notes and/or psychological assessment data is kept in locked storage files at the business address (see above) and is pseudonymised to ensure it cannot be linked to your name / identity.

Your personal data and relevant session material will be shared with my clinical supervisor (within the UK) but this is done in the strictest confidence in accord with the high ethical standards of practice governing the British Association of Counselling and Psychotherapy. If any data is sent electronically it would be done only rarely and, if necessary, with due pseudonymisation in place to protect your identity. This also would be sent via encrypted / password-protected means.

Your data will be retained for a maximum of 7 years depending on the stipulations of our current insurer and a minimum of 3 years in accord with the general practice within my professional body (BACP). Your electronic data will be deleted thereafter, and data stored on paper will be shredded.


Your data protection rights:

Under GDPR rules an organisation or individual can operate under the legal basis of ‘Legitimate Interests’. Haven Counselling and Coaching operate under this basis which means that you have:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.

However, you do not have the right to data portability -ie the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances and you should be aware that if we have reasonable grounds to continue processing or retaining your data in the view of the Information Commissioner’s Office, we may continue to do so.


How to complain:

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Helpline number: 0303 123 1113