Privacy policy
Gemma Capocci Counselling takes your privacy seriously. This policy explains how the personal information you supply on this website is used.
Introduction
This privacy notice provides you with details of how we collect and process your personal data when you:
use my website, including any information you may provide through our site when you contact me
complete any surveys I conduct
interact with me through social media, email or phone
By providing us with your data, you warrant to us that you are over 16 years of age.
Who am I
For the purpose of the Data Protection Act 1998 and the General Data Protection Regulation (GDPR), the data controller is Gemma Capocci Counselling. I am registered with the Information Commissioner’s Office, reference number C1352299 .
Contact Details
hello@gemmacapoccicounselling.com
07543508365
Postal address: 102 Harpenden Road, London, E12 5HN
If you are not happy with any aspect of how I collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I should be grateful if you would contact me first if you do have a complaint so that I can try to resolve it for you.
It is very important that the information I hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing me.
What data do I collect about you
Personal data means any information capable of identifying an individual. It does not include anonymised data.
I may process certain types of personal data about you as follows:
Identity Data may include your first name, last name, username, title, date of birth and gender.
Contact Data may include your billing address, delivery address, email address and telephone numbers.
Financial Data may include your payment card details (we do not save your payment card details).
Transaction Data may include details about payments between us and other details of purchases made by you.
Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
Profile Data may include your username and password, purchases or orders, preferences, feedback and survey responses.
Usage Data may include information about how you use my website and services.
Marketing and Communications Data may include your preferences in receiving marketing communications from me and your communication preferences.
I may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data
Sensitive Data
If you have had therapy with me and it has now ended, I will use legitimate interest as my lawful basis for holding and using your personal information. If you are currently having therapy or if you are in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of our contract. The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for me processing any special categories of personal information is that it is for provision of health treatment (in this case counselling) and necessary for a contract with a health professional (in this case, a contract between me and you).
How I collect your personal data
I collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on my site or by communicating with me by post, phone, email, social media, website chat or otherwise
Automated technologies or interactions: As you use my site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. I collect this data by using cookies, server logs and similar technologies. I may also receive Technical Data about you if you visit other websites that use our cookies. Please see the cookie policy for further details.
Third parties or publicly available sources: I may receive personal data about you from various third parties and public sources as set out below.
Technical Data from the following such parties:
analytics providers such as Google, Facebook & Twitter based outside the EU
advertising networks such as Google or Facebook based outside the EU
How I use your information
Initial contact.
When you contact me with an enquiry about my counselling services I will collect information to help me satisfy your enquiry. This will include your name, email address, telephone number and the reason you are coming to therapy. Alternatively, your GP or other health professional may send me your details when making a referral or a parent or trusted individual may give me your details when making an enquiry on your behalf. If you decide not to proceed I will ensure all your personal data is deleted within one month. If you would like me to delete this information sooner, just let me know.
While you are accessing counselling.
Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if I am concerned you may harm yourself or someone else. I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.
I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely on a GDPR compliant online system, accessed via my password protected laptop, and are not shared with any third party. I will keep short written notes of each session, these are kept on the same secure system. For security reasons I do not retain text messages for more than one month. If there is relevant information contained in a text message I will screen shot the text and save it on the same secure system. Likewise, any email correspondence will be deleted after one month if it is not important.
After counselling has ended.
Once counselling has ended your records will be kept for five years, as requested by my insurance company, and will then be securely destroyed.
Children's Privacy
I do not collect the personal data of children under the age of 16 without parental or guardian consent. If you believe that I hold any information from or about a child under age 16, please contact me and if we cannot immediately obtain appropriate parental or guardian consent, will remove the personal data from storage.
Purposes for processing your personal data
Set out below is a description of the ways I intend to use your personal data and the legal grounds on which I process such data. I have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us if you need details about the specific legal ground we are relying on to process your personal data.
Marketing communications
You will receive marketing communications if you have:
requested information
if you provided me with your details and ticked the box at the point of entry of your details for me to send you marketing communications
if you verbally agreed to receiving marketing communications
and, in each above case, you have not opted out of receiving that marketing
You can ask to stop sending you marketing messages at any time by following the opt-out links on any email marketing message sent to you or by emailing me.
Third party recipients of personal data
I sometimes share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks. In such cases I have carefully selected which partners I work with. I take great care to ensure that I have a contract with the third party that states what they are allowed to do with the data I share with them. I ensure that they do not use your information in any way other than the task for which they have been contracted. Third parties include:
WriteUpp – ISO27001 certified and GDPR compliant practice management software – where I store my client information and session notes
HM Revenue & Customs – client information shared for the purposes of processing my tax
Nina Mitchell Therapy – Clinical Supervisor – discussing aspects of client sessions to ensure I am working ethically according to the BACP framework
Information Commissioner’s Office (ICO) – UK’s independent authority set up to uphold information right’s in the public’s interest – potential to share client information if audited
Analytics tools that assist in the improvement and optimisation of our website (Google Analytics, Squarespace Analytics)
I require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. I only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
International Transfers
In most circumstances I do not transfer your personal data outside the European Economic Area (EEA). If using services providers that make international transfers of your personal data, I will only use service providers that follow US-EU Privacy Shield regulations or adhere to EU Standard Contractual Clauses.
I have identified the following service providers that may transfer your personal data outside the EEA:
Google Analytics – used for the analysis of our websites, pursuant to optimising our websites. Google is safeguarded under the US-EU Privacy Shield framework
Meta (Instagram,Facebook) – used for the analysis of marketing activity performance. Certified under the US-EU Privacy Shield framework
Data Security
I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
When you fill out any information on my website through your browser it will be encrypted before it is sent to us using a Secure Socket Layer (SSL).
I have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Retention
I will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, I consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law I have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing your personal data
Request transfer of your personal data
Right to withdraw consent
You can see more about these rights on the Information Commissioner’s Office (ICO) website (www.ico.org.uk).
If you wish to exercise any of the rights set out above, please email us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
I may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
I try to respond to all legitimate requests within one month. Occasionally it may take longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Questions and complaints
If you have a question regarding this Privacy policy or would like to make a complaint, please write to me:
by email: hello@gemmacapoccicounselling.com
by post: 102 Harpenden Road, London, E12 5HN