This privacy policy explains how Bailiwick Psychodynamic Counselling collects, uses, and protects any personal information you provide. Your privacy is very important to me 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 me.  I adhere to current data protection legislation and I am committed to ensuring your privacy is protected in accordance with the Data Protection (Bailiwick of Guernsey) Law, 2017 (https://www.guernseylegalresources.gg/laws/guernsey-bailiwick/d/data-protection/).

This privacy notice tells you what I will do with your personal information from initial point of contact through to after your therapy has ended, including:
•    Why I am able to process your information and what purpose I am processing it for,
•    How long I store it for,
•    Whether there are other recipients of your personal information, and
•    Your data protection rights.

I am happy to discuss any questions you might have about my data protection policy and you can contact me via the contact details below.

‘Data controller’ is the term used to describe the person/organisation that collects and stores and has responsibility for people’s personal data.

1. Identity and Contact Details
I am the Data Controller for this practice and am registered with the Office of the Data Protection Authority (ODPA).  If you have any questions regarding your data, please contact me at:
•    Name: Rebecca Humphries
•    Email: info@bpc.gg
•    Phone: 07911 727813

2. Lawful Basis for Processing
The GDPR states that I must have a lawful basis for processing your personal data.  There are different lawful bases depending on the stage at which I am processing your data.  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’.  I process your data under the following legal grounds:
•    Contractual Necessity: To provide the counselling services you have requested.
•    Legal Obligation: To maintain records for tax and accounting purposes.
•    Health & Social Care: As a healthcare professional, I process sensitive data for the provision of therapeutic treatment.
•    Legitimate Interests: To ensure the professional administration and safety of my practice.

3. The Data I Collect
I collect the following information to provide safe and effective counselling:
•    Personal Data: Name, date of birth, address, and contact details.
•    Special Category Personal Information: Notes from our sessions, health/medical history, and any sensitive information relevant to our counselling work.

4. Confidentiality
Everything we discuss is strictly confidential. I will not share your information without your consent, except in these specific cases:
•    Supervision: In line with professional ethics, I discuss my work with a clinical supervisor. Your identity is always anonymised.
•    Safety & Legal Requirements: I may breach confidentiality if there is a serious risk of harm to yourself or others, or if I am legally compelled by a court order or Guernsey law (e.g., safeguarding or terrorism).

5. Data Retention
•    Clinical Records: Notes are kept for 7 years after our final session, after which they are securely destroyed.
•    Financial Records: Basic invoice data is kept for 6 years for Guernsey Revenue Service compliance.
•    Enquiries: If we do not work together, your data will be deleted after 6 months.  If you would like me to delete this information sooner, just let me know.

6. Your Rights
I try to be as open as I can be in terms of giving people access to their personal information.  Under the Guernsey Data Protection Law, you have the right to:
•    Access a copy of your data (Subject Access Request), please put the request in writing addressing it to info@bpc.gg.
•    Request the correction of inaccurate data.
•    Request the erasure of your data (subject to legal retention requirements).
•    Withdraw your consent for data processing at any time.

7. Complaints
If you have concerns about how I handle your data, please contact me first.  I would welcome any suggestions for improving my data protection procedures.  You also have the right to lodge a formal complaint with the Office of the Data Protection Authority (ODPA).

8. Data Security
I take the security of the data I hold about you very seriously and as such I take every effort to make sure it is kept secure.  I use securely encrypted IT devices, consisting of a laptop and a smartphone, that are only used by me, and data is password protected at both the level of the individual document and the device itself.  Any paper documents are locked in a robust non-portable cabinet to which only I have access.  

9. Visitors to my Website
When someone visits my website, I use a third party service, IONUS, to collect standard internet log information and details of visitor behaviour patterns.  I do this to find out things such as the number of visitors to the various parts of the site.  This information is only processed in a way that does not identify anyone.  I do not make, and do not allow IONUS to make, any attempt to find out the identities of those visiting my website.
I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.  I use IONUS so that I can continually improve my service to you, you can read their privacy notice here.  No user-specific data is collected by me or any third party.  If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.

10. Cookie Policy
My website uses cookies to improve your experience.  Cookies are small text files placed on your device to help the site provide a better user experience.

Types of Cookies We May Use
•    Strictly Necessary Cookies: These are essential for the website to function securely and properly (e.g., security tokens for contact forms or session identifiers). These cannot be turned off.
•    Analytical Cookies (Optional): We may use tools like Google Analytics to understand how visitors interact with the site. This helps us improve our services. These are only placed if you "Accept" them via our cookie banner.
•    Functional Cookies: These remember your preferences, such as language settings or if you have already dismissed a notification. 
Managing Cookies
•    You can choose to accept or decline non-essential cookies via the banner that appears when you first visit the site. 
•    You can also manage or delete cookies directly through your web browser settings at any time.