Privacy Policy

I, Ben Foster am the Data Controller and Processor of Ben Foster Therapy.

The basis on which I keep client data is that of “Legitimate Interests”. This means that the data is necessary for me to fulfil the contract that we have together (i.e. to provide therapy) and that it is data that you would reasonably expect me to hold and use.

For those who enquire about therapy, the data I hold includes any information you have sent me by email/text/message.

For those who book and attend at least one session (including the initial contact), the data I hold includes:

  • Basic information such as name, email address, phone number.

  • Information that you give me as part of the work we do together.

  • Audio recordings of each session.

  • Records of what interventions that I use (or potentially do not use) in our sessions.

  • Emails, texts and/or messages that are sent between us.

  • Information sent from any third party, e.g. GP, insurance company, EAP, occupational health provider.

Some of the information that you give me may fall under the definition of special category of data as defined by the General Data Protection Regulation (GDPR). The condition for processing this special data is “processing is necessary for medical diagnosis, the provision of health care or treatment pursuant to contract with a health professional”. Examples of special category of data could include information about your health, race, sexuality, sex life, or religion. This implies that if you decide to start counselling with me or enquire about your eligibility for counselling, I will probably have to handle some special category data related to you. Typically, this information pertains to your mental health or medical data, essential for providing you with secure and efficient counselling services as per our contractual commitments.

Data is not shared with anyone, except possibly your GP, and for any reasons covered by the Limits of Confidentiality which are detailed and discussed when we first meet. My accountant will see bank transfers and payment card (e.g. debit/credit card) transactions which will contain any information that you submit when making a payment. If you would like me to redact your identifiable data before sending to my accountant then please let me know.

The data is primarily used to enable me to provide therapy for you and for my capacity as a therapist to be assessed via supervision. It may also be used for scientific research purposes and statistical purposes.

Details of where data is held:

  • Any emails sent between us are held either on my laptop’s hard drive or exchange server and my laptop is fingerprint/password protected. Any that may be held on my mobile phone are Face ID/code protected.

  • Any text messages sent between us (See Social Media and Electronic Information section) are held on my mobile phone which is Face ID/code protected.

  • Your notes are handwritten and are kept in a locked box. A coding system (i.e. initials) enables the therapist to know whose notes are whose, but a stranger seeing the notes would not be able to identify who they referred to.

  • Payment card information is shredded as soon as processed.

Your data is kept for 7 years. The length of time is based on the stipulation of my insurer. After this time any paper records are shredded and computer records permanently deleted.

I take the security of data seriously and as such:

  • All data is held securely (see details of where data is held above).

  • Any data transmitted is sent encrypted where possible.

  • For accounting purposes Excel spreadsheets are used.

  • I use a secure payment provider for accepting card payments – Stripe. In order to ensure the security of your data, I am anonymising your payment references by coding them when I am exporting these for accounting purposes. The codes matching them to your contact details are stored in a locked box.

If there is any breach of data security, I will give full details to the Information Commissioners Office and any person affected within 72 hours of the breach and do all possible to minimise any potential impact.

You have rights with regards to the data held:

  • The right of access. I will provide you with all data I hold on you as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).

  • The right to rectification. If any data I hold is incorrect, just let me know and I will correct it as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).

  • The right to erasure. If you wish me to erase your data just let me know and I will delete any computer records and shred any paper records as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness). NB: data may be retained for scientific research, historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing but this would never include case notes or data such as address/email/phone number.

  • The right to restrict processing. This would usually be a stop-gap measure before correction of any errors or before erasure

  • The right to data portability. This might apply if you want your notes sent to another therapist for example, but it is likely that the easiest solution would come under the right to access, i.e. I would send the data to you.

  • The right to object to:

    • Processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling). I do not engage in these things.

    • Direct marketing.

    • Processing for purposes of scientific/historical research and statistics. For this, you must provide grounds for your objection.

    • Automated decision making and profiling. I do not engage in automated decision making or profiling.

Cookies

Like many websites, I use cookies. A cookie is a small amount of data that is sent to your computer or mobile phone browser from a website’s computer and is stored on your device’s hard drive.

Cookies record information about your online preferences. They help me understand how visitors engage with my sites so that I can improve your online experience with me at Ben Foster Therapy. I do not use cookies to collect personally identifiable information about you.

Each website you visit can send its own cookie to your browser if your browser’s preferences allow it. To protect your privacy, your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites.

How to control and delete cookies;

You may restrict or block the cookies which are set by our website, or any other website, through your browser settings. You can also ask your browser to alert you when a cookie is issued.

For more information about cookies and how to manage them is available at www.aboutcookies.org

I use Google Analytics to understand how visitors engage with my websites. It collects information anonymously and reports website trends without identifying individual visitors. For more information visit Google Analytics privacy and security information.