GDPR Policy - Jay Clarke – Therapy Up North
The collection and storage of personal information
In accordance with the General Data Protection Regulation (GDPR) 2018, which regulates how personal information is collected, stored and shared, I (Jay Clarke) am registered with the Information Commissioners Office (ICO); I am responsible for the handling and processing of all data/information related to my business, Therapy Up North. Any person accessing Therapy Up North services (referred to as the client below) is requested to read and consent to this GDPR policy. Please feel free to contact me with any questions you may have.
Personal information I collect
- Name and date of birth – how you would like to be known and how old you are
- Address – where you are currently living
- Telephone number – permission to call and leave messages
- E-mail address – permission to email
- Online address – permission to call and leave messages should you wish to meet via video
- Medical, background and assessment information
- GP details and an emergency contact – in the event of a medical emergency
How I store and utilise personal information in my business
Electronic:
Mobile phone: my mobile phone is used solely by me and is password protected.
Laptop computer: my laptop is used solely by me and is password protected.
Paper documents:
- Registration details, case sheet and session notes
- Working agreement and GDPR agreement
Any initial case sheet that you complete and bring with you or send via email is printed out and allocated a reference code, your name is not on this document. Any session notes I make are anonymised and allocated the reference code, your name is not on these documents. Client’s names and contact and registration details are kept separate from case sheets and session notes. All paperwork is stored in a lockable cabinet that is only accessible to me, or in the event of my death or incapacitation, my therapeutic executor (please see below).
How I may process / share personal information
Consultation - As a practitioner registered with the British Association for Counselling and Psychotherapy, I am ethically required to have clinical supervision. Supervision supports, upholds and enhances best practice and professional standards, ultimately for the safety and well-being of the client. Supervision is a confidential process, however, to augment privacy and confidentiality, I do not share client names or identifying features in supervision.
Therapeutic will - In the event of my death or incapacitation secure access to client contact details would be transferred to a therapeutic executor who would assume data control. The purpose of the transfer would be to ensure clients could be contacted and informed of the situation and support offered. In the event of my death, client information and any session notes would be destroyed by the therapeutic executor.
Emergencies - I would seek client consent before sharing any information, however, if there was a serious risk to a person’s life/health, I may share some information with emergency/medical services, without client consent being given. Practitioners are legally bound to share certain information with an authority, for example, terrorist activity, money laundering, drug trafficking and when information is requested by a court of law.
Deleting information - I keep client data/information for up 7 years after the work has ended, it is then deleted/destroyed.
Your rights - You have the right to:
- Be informed about how and why your information is held (this document).
- Request to see any information held about you (please allow 30 days).
- Withdraw consent to any information being used/held (although this may mean it is no longer possible to access counselling).
- Request personal details to be changed, corrected, completed or erased (original case sheets and session notes need to be retained for legal reasons).
If you have read and understood this document and consent to your information being collected, stored, and used in this way, please consent by signing and dating the following statement below. Thank you.
I consent to Jay Clarke holding and processing the information contained in this form, for the purposes of providing Therapy Up North services, in accordance with the principles of the General Data Protection Regulation (GDPR) 2018.
Signature Name (PRINTED) Date
Therapy Agreement (private referral)
Sessions: The time, duration, place and modality (face to face, telephone, online) of sessions will be pre-arranged between the client and the therapist. Both agree to work together in a therapeutic way. If the client lacked capacity for a session, for example, was affected by ill health / alcohol / substances, therapy would not go ahead.
If further sessions were agreed after the initial session, there would be a review after four sessions, then, if it was agreed that sessions continue, there would be periodical reviews. An ‘ending session’ is recommended.
If the client did not attend a session and did not contact the therapist, the therapist may contact the client to establish the position regarding continuing or ending. If the client did not respond the therapist would assume their work together had ended. If the therapist needed to cancel or delay a session, they would aim to inconvenience the client as little as possible.
Unless there is a pre-agreed agreement, there is a ‘phones off’ and ‘no recording’ policy. If a telephone or online session is arranged, the therapist will call the client at the agreed time, both agree their environments will be conducive for therapy.
Fees are to be paid by the client on the day of the session by cash or bank transfer to Ms J Clarke, account: xxxxx, sort code: xxxxx 72 hours notice of cancellation is required. If the client needs to cancel, they can email the therapist at anytime or can call or leave an answerphone message between 9am-8pm on xxxxx. The fee also applies to a cancelled/missed session with less than 72 hours notice and if lack of capacity occurred. Any outstanding fees are to be paid within 7 days.
Confidentiality: What the client says and experiences in therapy will be treated as confidential by the therapist. If an exceptional situation occurred, for example, an escalating risk to safety or if the therapist was legally required to do so, confidentiality may need to be extended. If this occurred, where possible, there would be a discussion beforehand between the therapist and the client. UK law applies. The therapist discusses casework in a professional and anonymised way in clinical supervision. In the event of the death/incapacitation of the therapist an appointed person would contact the client. Information relating to the client will be kept and disposed of in line with General Data Protection Regulation (GDPR) principles.
Ethics: The therapist follows the ethical framework of The British Association for Counselling and Psychotherapy (BACP). The client is encouraged to discuss anything relating to the therapy with the therapist, if unresolved, the client can contact The BACP directly for guidance.
Other boundaries: The client agrees to inform the therapist of any treatment from other practitioners or any civil/criminal proceedings they may be involved in. Both agree to inform each other of changes that may affect their work together and any wish to review this agreement.
The content of our exchanges are not for publication on social media/public forums.
Anything to add:
Therapeutic Group Agreement
‘Group’ is a confidential setting. All agree not to disclose other members, experiences, information or identities outside of group. All agree to take responsibility for what they say and do by respecting themselves and each other. Members agree to make a commitment with themselves and to group by attending as many sessions as possible. If a member cannot attend at the agreed time they agree to inform other members in advance (e.g. if going on holiday) or via the therapist (e.g. if ill or late). Members may contact the therapist or leave an answerphone message between 9am-8pm on xxxxx or email therapyupnorth@gmail.com anytime.
Contact with each other is only appropriate during sessions unless negotiated otherwise with the therapist and group. The two hour group sessions are pre-arranged. In the event of two or less group members being present the meeting time may be reduced. If the therapist needed to cancel or delay a session, they aim to ensure members are inconvenienced as little as possible. Group would not meet if the therapist was not available (e.g. ill). All agree to work in a respectful, therapeutic and safe way. If anyone lacked capacity for a session, for example, was affected by ill health / alcohol / substances, they agree not to attend or would accept an invitation to leave group for that session.
All agree to give at least one session notice of intention to leave group (in person if possible, if not via the therapist). If a member does not attend group and does not make contact for a month, group will assume the member no longer wishes to be in group. The therapist may contact the absent member to establish the position regarding continuing or ending if they do not respond before the next group session the therapist will assume they have ended. All members will be consulted in the process of a new person being invited to join group.
The therapist respects members by following the ethical framework of The British Association for Counselling and Psychotherapy (BACP). Members are encouraged to discuss anything relating to the therapy with the therapist, if unresolved, the BACP can be contacted for guidance.
If an exceptional situation occurred, for example, an escalating risk to safety or if the therapist was legally required to do so, confidentiality may need to be extended. If this occurred, where possible, there would be a discussion beforehand between the therapist and the member/s. The therapist discusses casework in a professional and anonymised way in clinical supervision. In the event of the death/incapacitation of the therapist an appointed person would contact members. Information relating to members will be kept and disposed of in line with General Data Protection Regulation (GDPR) principles.
The group fee is to be paid by members on the day of the session by cash, cheque or bank transfer to Ms J Clarke, account: xxxxxxxx, sort code: xxxxxxxx (irrespective of attendance or not). There will be no charge if the therapist is not available. Members agree to secure their place before joining group with a sessional payment and therefore no payment is required at the final session.
All agree to inform group of any changes that may affect their work together and this agreement can be reviewed at the request of any member. Group members agree to inform the therapist of any treatments they receive from other practitioners or any civil or criminal proceedings they may be involved in.
Unless there is a pre-agreed agreement, there is a ‘phones off’ and ‘no recording’ policy.
The content of our exchanges are not for publication on social media/public forums.
Therapy Agreement (company referral)
Sessions: The time, duration, place and modality (face to face, telephone, online) of sessions will be pre-arranged between the client and the therapist. Both agree to work together in a therapeutic way. If the client lacked capacity for a session, for example, was affected by ill health / alcohol / substances, therapy would not go ahead.
If further sessions were agreed after the initial session, there would be a review half way through the allocated sessions. An ‘ending session’ is recommended. The maximum number of sessions stated by the referring company cannot be exceeded.
If the client did not attend a session and did not contact the therapist, the therapist may contact the client to establish the position regarding continuing or ending. If the client did not respond the therapist would assume their work together had ended; the client should contact the referring company for further information/support. If the therapist needed to cancel or delay a session, they would aim to inconvenience the client as little as possible.
Unless there is a pre-agreed agreement, there is a ‘phones off’ and ‘no recording’ policy. If a telephone or online session is arranged, the therapist will call the client at the agreed time, both agree their environments will be conducive for therapy.
72 hours notice of cancellation is required. If the client needs to cancel, they can email the therapist at anytime or can call or leave an answerphone message between 9am-8pm on 0161 860 7378. Sessional fees are to be paid by the referring company. Fees also apply to a cancelled/missed session with less than 72 hours notice and if lack of capacity occurred. A cancelled or missed session with less than 72 hours notice is counted within the allocation.
Confidentiality: What the client says and experiences in therapy will be treated as confidential by the therapist. If an exceptional situation occurred, for example, an escalating risk to safety or if the therapist was legally required to do so, confidentiality may need to be extended. If this occurred, where possible, there would be a discussion beforehand between the therapist and the client. UK law applies. The therapist discusses casework in a professional and anonymised way in clinical supervision. In the event of the death/incapacitation of the therapist an appointed person would contact the client. Information relating to the client will be kept and disposed of in line with General Data Protection Regulation (GDPR) principles. If any information is required by the referring company it will be discussed between the client and the therapist and kept to a minimum.
Ethics: The therapist follows the ethical framework of The British Association for Counselling and Psychotherapy (BACP). The client may discuss anything relating to the therapy with the therapist, if unresolved, the client can contact The BACP directly for guidance.
Other boundaries: The client agrees to inform the therapist of any treatment from other practitioners or any civil/criminal proceedings they may be involved in. Both agree to inform each other of changes that may affect their work together and any wish to review this agreement.
The content of our exchanges are not for publication on social media/public forums.
Anything to add:
Therapy Agreement for couples work
Sessions: The time, duration, place and modality (face to face, telephone, online) of sessions will be pre-arranged between the client and the therapist. The clients and the therapist all agree to work together in a therapeutic way. If one of the clients lacked capacity for a session, for example, was affected by ill health / alcohol / substances, therapy would not go ahead. If further sessions were agreed after the initial session, there would be a review after four sessions, then, if it was agreed that sessions continue, there would be periodical reviews. An ‘ending session’ is recommended.
If one or both of the clients did not attend a session and did not contact the therapist, the therapist may contact the clients to establish the position regarding continuing or ending. If the clients did not respond the therapist would assume their work together had ended. If the therapist needed to cancel or delay a session, they would aim to inconvenience the clients as little as possible.
Unless there is a pre-agreed agreement, there is a ‘phones off’ and ‘no recording’ policy. If a telephone or online session is arranged, the therapist will call the clients at the agreed time, all agree their environments will be conducive for therapy.
Fees are to be paid by the clients on the day of the session by cash, cheque or bank transfer to Ms J Clarke, account: xxxxxxxx, sort code: xxxxxxxx 72 hours notice of cancellation is required. If the clients need to cancel, they can email the therapist at anytime or can call or leave an answerphone message between 9am-8pm on 0161 860 7378. The fee also applies to a cancelled/missed session with less than 72 hours notice and if lack of capacity occurred. Any outstanding fees are to be paid within 7 days.
Confidentiality: What the clients say and experience in therapy will be treated as confidential by the therapist. Confidentiality does not apply between the therapist and the couple, i.e. information shared with the therapist by one partner may be shared with the other partner. If an exceptional situation occurred, for example, an escalating risk to safety or if the therapist was legally required to do so, confidentiality may need to be extended. If this occurred, where possible, there would be a discussion beforehand between the therapist and the client. UK law applies. The therapist discusses casework in a professional and anonymised way in clinical supervision. In the event of the death/incapacitation of the therapist an appointed person would contact the client. Information relating to the client will be kept and disposed of in line with General Data Protection Regulation (GDPR) principles.
Ethics: The therapist follows the ethical framework of The British Association for Counselling and Psychotherapy (BACP). Clients are encouraged to discuss anything relating to the therapy with the therapist, if unresolved, the client can contact The BACP directly for guidance.
Other boundaries: The clients agree to inform the therapist of any treatment from other practitioners or any civil/criminal proceedings they may be involved in. All agree to inform each other of changes that may affect their work together and any wish to review this agreement.
The content of our exchanges are not for publication on social media/public forums.
Anything to add:
Supervision Agreement
The supervisor commits to supporting, challenging and encouraging the supervisee to continually develop themselves and a good and ethical practice. The supervisee commits to continually developing themselves and their practice. Both agree to continually work for the benefit of clients. The supervisee agrees to prepare an agenda for supervision sessions; the supervisor may add items if appropriate. Appropriate items for supervision include content and process issues, development and ethical issues, practitioner wellbeing, boundaries, reviews, workload, interventions and strategies.
Sessions: The time, duration, place and modality (face to face, telephone, online) of sessions will be pre-arranged between the client and the therapist. If the supervisee lacked capacity for a session, for example, was affected by ill health / alcohol / substances, supervision would not go ahead. Supervisory contact is only appropriate during these pre-arranged times (unless there is an emergency).
Unless there is a pre-agreed agreement, there is a ‘phones off’ and ‘no recording’ policy. If a telephone or online session is arranged, the supervisor will call the supervisee at the agreed time, both agree their environments will be conducive for supervision.
The fee is to be paid by the supervisee on the day of the session by cash or bank transfer to Ms J Clarke, account: xxxxx sort code: xxxxx 72 hours notice of cancellation is required. If the supervisee needs to cancel or reschedule, they can email the supervisor at anytime or they can leave a voice message between 9am-8pm on xxxxx or on the day of the session call xxxxx. The fee also applies to a cancelled/missed/rescheduled session with less than 72 hours notice or if lack of capacity occurred. If the supervisor needs to cancel or delay a session they aim to ensure the supervisee is inconvenienced as little as possible.
An ‘ending session’ is recommended. If the supervisee did not attend a session and did not contact the supervisor, the supervisor may contact the supervisee to establish the position regarding continuing or ending. If the supervisee did not respond the supervisor would assume their work together had ended. Any outstanding fees are to be paid within 7 days.
Confidentiality: What the supervisee says and experiences in supervision will be treated as confidential by the supervisor. If an exceptional situation occurred, for example, an escalating risk to safety or if the supervisor was legally required to do so, confidentiality may need to be extended. If this occurred, where possible, there would be a discussion beforehand between the supervisor and supervisee. The supervisor discusses casework in a professional and anonymised way in clinical supervision. In the event of the death/incapacitation of the supervisor an appointed person would contact the client. UK law applies. Information relating to the supervisee will be kept and disposed of in line with General Data Protection Regulation (GDPR) principles.
Ethics: Both agree to respect each other and work in a professional and ethical way by working within the ethics and frameworks of organisations they work within and are affiliated to. Both agree to be qualified and have professional indemnity insurance for all services provided. Supervisees are encouraged to discuss any dissatisfaction or concerns about the supervision with the supervisor, if unresolved, the supervisee can contact The BACP directly for guidance as the supervisor is a registered BACP member.
Other boundaries: The supervisee agrees to inform the supervisor of any alliances/treatments from other practitioners or any civil/criminal proceedings they may be involved in. Both agree to inform each other of changes that may affect their work together and any wish to review this agreement. The content of our exchanges are not for publication using social media or public platforms.
Anything to add:
Meeting in an outdoor setting (additional points to our working agreement and further additional points re COVID).
Thank you for arranging an outdoor meeting. Please consider the following points, they are offered with comfort and safety in mind. We can discuss the points further, when we meet, or beforehand if that helps.
Please come prepared for the climate and terrain by considering comfortable and practical clothing and footwear, i.e: clothing which will keep you dry, warm, cool, protected from the sun, protected from insects and walking footwear which has a grip (e.g. waterproofed walking boots/shoes, trainers, wellies, walking sandals).
Other things you may wish to consider for your comfort and safety:
o Medication – please bring any medication which you may require with you (if you have asthma, diabetes, heart condition, hay fever, etc).
o Water.
o Suncream. Hat. Sunglasses. Insect repellent.
o Umbrella, walking pole/s or a sit mat if you think you may want them.
It is possible we will encounter changing weather conditions, other people, unleashed dogs and other things which are a natural part of being outside.
Please continue to use my usual contact details to make or reschedule meetings or to make enquiries: email therapyupnorth@gmail.com and telephone xxxxx. However, if you need to contact me on the day of our outdoor meeting to let me know you will be delayed or not attending, use this phone number: xxxxx. Please only use this number only on the day and for this purpose only.
If you will be parking a vehicle nearby, ensure valuables are not on display and that your vehicle is secure. Finally, let us agree to follow the countryside code by respecting the land, plants, trees, animals and birds and leave no trace of our visit by leaving any litter or by unnecessarily disturbing nature.
I look forward to our meeting outside. With best wishes, Jay.
COVID care - If you are isolating, feel unwell, have or think you may have coronavirus symptoms or simply just prefer to meet by video/telephone, please let me know ahead of our meeting and we can revert to a video/telephone meeting or reschedule. I am still maintaining physical distance during outdoor meetings. Thank you in advance for your understanding. Please make payment on the day online, my bank details are: xxxxx | 
