Xanthe Fry Registered MBACP (Accred) Counsellor and Psychotherapist in Oxford


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, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
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
• Whether you have to provide it to me
• How long I store it for
• Whether there are other recipients of your personal information
• Whether I intend to transfer it to another country,
• Whether I do automated decision-making or profiling, and
• Your data protection rights.

I am happy to chat through any questions you might have about my data protection policy and you can contact me via email on [email protected]

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

I am registered with the Information Commissioner’s Office.

My lawful basis for holding and using your personal information

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. I have explained these below:

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 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 name, contact details, reason for referral/enquiry, agreed next steps (e.g. an appointment date). 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 12 months. If you would like me to delete this information sooner, just let me know.

While you are accessing counselling:

It is important that everything you discuss with me is confidential. That confidentiality will only be broken if I become aware that you or another person are at serious risk of harm. This includes a UK legal requirement to disclose information regarding terrorism (Terrorism Act 2000). A court is also able to make a court order that I share information from counselling. 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 in a locked filing cabinet in a different, secure place to the counselling venue. Any details from emails or phone calls are on a password protected laptop and password and finger-print protected smartphone, and are not shared with any third party.

I will keep written notes of each session. These are kept in a locked filing cabinet, as above, but are coded in order to anonymise them, and are stored separately from the personal details.

For security reasons I do not retain text messages for more than 12 months. If there is relevant information contained in a text message I will make a note of it with the session notes. Likewise, any email correspondence will be deleted after 12 months if it is not important. If
necessary I will keep a record of email correspondence within the session notes, and will file the email within my password protected counselling email account.

After counselling has ended:

Once counselling has ended your records will be kept for 7 years from the end of our contact with each other (or until age 25 if you are under 18 at the time of counselling), and are then securely destroyed. This is in line with recommended professional guidelines. If you want me to delete your information sooner than this, please tell me.

Your rights

I try to be as open as I can be in terms of giving people access to their personal information. I aim to treat all my clients as I would like to be treated. You have a right to ask me to delete your personal information, to limit how I use your personal information, or to stop processing your personal information. You also have a right to ask for a copy of any information that I hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at ico.org.uk/your-data-matters.

If I do hold information about you I will:
• give you a description of it and where it came from;
• tell you why I am holding it, tell you how long I will store your data and how I made this decision;
• tell you who it could be disclosed to;
• let you have a copy of the information in an intelligible form.

You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you. To make a request for any personal information I may hold about you, please put the request in writing addressing it to [email protected]

If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by emailing to the contact details given above. I would welcome any suggestions for improving my data protection procedures.

If you want to make a formal complaint about the way I have processed your personal information you can contact the ICO which is the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint.

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 receive and reply to emails on a laptop and smartphone which are password and/or fingerprint protected. Written personal details (name, contact details) are stored in a locked filing cabinet, and in a secure, locked building, away from the counselling venue. Notes related to sessions are written with a code to identify them, and not a name. These are stored in a locked filing cabinet, as above, but in a separate place to the personal details, so that they are not linked.

Additional information for visitors to my website:

When someone visits my website, I use a third party service, WebHealer, to collect standard internet log information and details of visitor behaviour patterns. WebHealer are a webhosting company who specialise in services for therapists and health professionals. 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. No user-specific data is collected by me or any third party. I do not make, and do not allow WebHealer to make, any attempt to find out the identities of those visiting my website.

Furthermore, when an enquiry is submitted via my website, WebHealer send the email direct to my counselling email address, and then delete the message from their systems. They retain the enquiry only until they are confident it has been successfully delivered.

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 WebHealer so that I can continually improve my service to you, You can read WebHealer's privacy notice here: https://www.webhealer.net/privacy

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If you have any questions about any aspect of my Privacy Policy, please contact me.

Thank you.

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