Privacy Policy

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 my email: Ben.Milner.Therapy@pm.me

‘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 myself, Ben Milner.

I am registered with the Information Commissioner’s Office: ZC062634. 

My name is:    Ben Milner Therapy T/A City & Coast Counselling.

My postal address is:   19 Carisbrooke Road, St Leonards-on-Sea, TN38 0JN

My phone number is:   07590546666

My email address is:   Ben.Milner.Therapy@pm.me

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 consent initially. I will then retain any counselling records in case of the need to reference

them in the future (the official legal basis is to defend against potential legal claims).

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 and contact details, plus any personal data you chose to disclose to me. 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 7 years. 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 there is significant risk of harm to you or a third party, or for the reasons laid out in the contract we agree. 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 using a Proton Drive encrypted online storage, behind two factor authentication accessible only by myself. They are not shared with any third party. All records are written without identifiable client information, in order to maintain strict confidentiality. 

I will keep written notes of each session, these are kept in a secure safe between sessions and, once transferred to electronic form at the end of our relationship, are destroyed. Client notes contain very brief, factual and concise details of what was discussed in session. They do not contain any personal opinions of the therapy. 

For security reasons I do not retain text & WhatsApp messages for more than 30 calendar days. If there is relevant information contained in a text message I will transfer this to the client notes electronically and delete the text. Likewise, any email correspondence will be deleted after 6 calendar months if it is not important. If necessary I will transfer this to the client notes electronically and delete the original email.

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 and are then securely destroyed. If you want me to delete your data sooner than this, please tell 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.

These Third party recipients are currently limited to; Proton Drive, for the encrypted online storage of my client notes and records, my Clinical Supervisor who oversees my client work and the British Association of Counsellors and Psychotherapists (BACP) who may audit my practice from time to time. 

Your rights

I try to be as open as I can be in terms of giving people access to their personal information. 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 Ben.Milner.Therapy@pm.me .

If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by writing or 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 use an encrypted online Proton Drive, behind two factor authentication. I have a safe, locked and secured for paper files. All personally identifiable data is pseudonymised.