‍ ‍

Privacy Notice

Noon Counselling & Psychotherapy
Including Noon Workplace Wellbeing‍ ‍ ‍

1. About this Privacy Notice

This Privacy Notice explains how Noon Counselling & Psychotherapy collects, uses, stores and protects personal information in connection with my counselling, psychotherapy and workplace wellbeing services.

Noon Counselling & Psychotherapy is operated by Thomas Noon, a UKCP Accredited Psychotherapeutic Counsellor.

This notice applies to:

·       individuals who contact me about counselling or psychotherapy;

·       individuals who receive counselling through Noon Workplace Wellbeing;

·       employers and organisations who engage Noon Workplace Wellbeing; and

·       individuals who contact me through my website or other communication channels.

I am committed to protecting your privacy and handling personal information fairly, transparently and securely.

2. Data Controller

I, Thomas Noon, trading as Noon Counselling & Psychotherapy, am the data controller responsible for the personal information I process in connection with my services.

A data controller is responsible for deciding why personal information is collected and how it is used.

Where I use external organisations to provide services to my practice, such as website hosting, email, video-conferencing or practice-management systems, these organisations may process information on my behalf or act as separate controllers depending on the service and processing involved.

3. How I use your information

I only collect and use personal information where it is necessary for purposes such as:

·       responding to enquiries;

·       providing counselling or psychotherapy;

·       arranging and administering appointments;

·       providing Noon Workplace Wellbeing services;

·       managing agreements with employers;

·       communicating with employees and organisations;

·       maintaining appropriate professional records;

·       meeting professional, legal and regulatory obligations;

·       protecting the safety and wellbeing of individuals;

·       managing payments and business administration; and

·       maintaining the security and operation of my website and systems.

Different types of processing may rely on different lawful bases. Under UK data protection law, a lawful basis must be identified for personal-data processing, and health information requires an additional condition because it is special category data.

4. Information I collect

Contact information

This may include:

·       name;

·       email address;

·       telephone number;

·       correspondence details.

I collect this information so that I can respond to enquiries, arrange appointments and communicate with you appropriately.

If you make an enquiry but decide not to proceed with counselling, I will normally retain your enquiry information for up to six months, after which it will be securely deleted unless there is a legitimate reason for retaining it for longer.

5. Counselling and psychotherapy information

If you decide to proceed with counselling or psychotherapy, I may collect additional information necessary to provide an appropriate and safe therapeutic service.

This may include:

·       age and date of birth;

·       relevant personal circumstances;

·       information relating to your wellbeing;

·       information about your mental or physical health;

·       medication information where relevant;

·       GP or healthcare contact details where necessary;

·       information discussed during assessment and therapy; and

·       other information relevant to your therapeutic work.

Health information is treated as special category personal data and is subject to additional protection under UK GDPR.

I only collect information that is relevant and necessary for the provision of the service.

6. Noon Workplace Wellbeing

Noon Workplace Wellbeing provides organisations with access to workplace wellbeing support, which may include confidential counselling, manager wellbeing resources and workplace wellbeing strategy reviews.

Where an employee accesses counselling through Noon Workplace Wellbeing, the therapeutic relationship is between the employee and therapist.

The employer is not a party to the therapeutic relationship and will not have access to the employee's counselling records or the content of counselling sessions.

Employers will not be provided with information about:

·       why an employee has accessed counselling;

·       what an employee discusses during counselling;

·       the employee's therapeutic progress;

·       clinical information;

·       counselling notes; or

·       other confidential therapeutic information.

7. Information provided to employers

An employer may receive limited administrative information where this is necessary to administer the agreed Workplace Wellbeing service.

This may include information relating to:

·       the agreed membership or service arrangement;

·       allocated counselling credits;

·       whether the workplace wellbeing service has been accessed; and

·       whether allocated credits have been used.

The purpose of providing this limited information is to allow the employer to administer and evaluate the service while protecting the confidentiality of individual employees.

Protecting employee privacy

Where providing usage information could reasonably create a risk that an individual employee could be identified, individual usage information will not be supplied.

In particular, where an organisation has fewer than 10 employees, individual usage information will not be provided to the employer for the purpose of identifying service users.

Instead, the employer may simply be informed that the relevant workplace wellbeing allocation or counselling credits have been used.

This approach is intended to minimise the risk of individuals being identifiable from service-use information.

For larger organisations, any information provided will remain limited to what is necessary for the administration and evaluation of the agreed service and will not include confidential therapeutic information.

8. The therapeutic relationship

Where counselling is provided through Noon Workplace Wellbeing, the employee remains the client of the counselling service.

The employer does not determine the content of counselling and does not receive information about the employee's therapeutic work.

Before counselling begins, employees will be provided with information about confidentiality, its limits and how their personal information will be handled.

A separate Employee Counselling Agreement will apply to the therapeutic relationship.

9. Confidentiality

Everything discussed within counselling sessions is treated as confidential.

There are circumstances where confidentiality may need to be breached, including:

·       where there is a serious and imminent risk of harm to yourself or another person;

·       where there are safeguarding concerns relating to a child or vulnerable adult;

·       where disclosure is required by law or court order; or

·       where disclosure is required to meet a professional regulatory or ethical obligation.

Where appropriate and possible, I will seek to discuss any proposed disclosure with you beforehand.

Any disclosure will be limited to the information that is necessary and proportionate to the circumstances.

10. Therapeutic notes

I keep brief therapeutic notes relating to counselling sessions.

These notes are confidential and are accessible only to me, except where disclosure is required by law or a professional obligation.

You may request access to personal information I hold about you, subject to applicable legal requirements and any relevant exemptions.

Therapeutic records will normally be retained for seven years following completion of therapy, in accordance with my professional, insurance and record-keeping requirements.

After the applicable retention period, records will be securely destroyed or deleted.

11. Supervision

As a practising counsellor, I undertake professional supervision.

I may discuss aspects of my therapeutic work with my supervisor for the purposes of professional reflection, clinical support, ethical practice and maintaining appropriate professional standards.

Where cases are discussed, I take steps to ensure that clients are not identifiable wherever possible.

Your full name, address and other unnecessary identifying information will not ordinarily be disclosed to my supervisor.

12. Online counselling

Where counselling sessions are conducted online, I use Zanda connected with Zoom.

These systems are used to support the secure delivery and administration of online counselling.

While reasonable steps are taken to protect confidentiality and security, no online communication system can be guaranteed to be completely secure.

Clients are encouraged to attend online sessions from a private and secure environment and to use a trusted internet connection where possible.

13. Website contact form

If you submit an enquiry through my website, the information you provide will be used to:

·       respond to your enquiry;

·       communicate with you about the service; and

·       assess whether my services may be appropriate for your needs.

Please avoid including highly sensitive personal or health information in an initial website enquiry where possible.

If you decide not to proceed with counselling, enquiry information will normally be deleted within six months.

14. Cookies and website data

My website is hosted by Squarespace.

Squarespace and other services used to operate the website may use cookies or collect technical information necessary for the operation, security and performance of the website.

Website analytics may also be used to understand general patterns such as the number of visitors to the website and the countries from which visitors access it.

Squarespace's own privacy information applies to the processing it undertakes as part of providing its services.

15. Email communication

Email communication is hosted by Microsoft Outlook.

For your privacy, I recommend keeping sensitive information shared by email to a minimum.

Email should primarily be used for arranging appointments and general communication rather than sharing detailed therapeutic or highly sensitive personal information.

16. How I protect your information

I take reasonable and appropriate steps to protect personal information against:

·       unauthorised access;

·       accidental loss;

·       inappropriate disclosure;

·       alteration; and

·       destruction.

Electronic information is stored using password-protected systems and devices.

Where physical records are held, these are stored securely and access is restricted to me.

17. Sharing your information

I will not sell your personal information or share it for marketing purposes.

I will not provide an employer with confidential counselling information about an employee.

Personal information may be shared where necessary:

·       with service providers who support the operation of my practice;

·       with my professional supervisor where appropriate and necessary;

·       where you have provided appropriate consent;

·       where required by law;

·       where necessary to protect vital interests;

·       where required to meet professional or regulatory obligations; or

·       where there is another lawful basis for doing so.

Where information is shared, I will seek to ensure that only the information necessary for the relevant purpose is disclosed.

18. Your rights

Under UK data protection law, you may have rights including:

·       The right to be informed about how your information is used.

·       The right of access to personal information I hold about you.

·       The right to rectification where information is inaccurate or incomplete.

·       The right to erasure, subject to circumstances where information must legally or legitimately be retained.

·       The right to restrict processing in certain circumstances.

·       The right to data portability, where applicable.

·       The right to object to certain processing.

·       Rights relating to automated decision-making and profiling, where applicable.

These rights are not absolute and may be subject to legal limitations depending on the circumstances.

19. Your contact details

Your contact information will only be used for legitimate purposes connected with my professional practice and the services you have engaged with.

I will not sell or use your contact information for unrelated marketing purposes.

Where you access Noon Workplace Wellbeing through your employer, your employer will not automatically receive your contact details simply because you have accessed counselling.

20. Complaints

If you have concerns about how your personal information has been handled, please contact me in the first instance.

Thomas Noon
Noon Counselling & Psychotherapy

Email: tom@nooncounsellingandpsychotherapy.co.uk
or
noon.psychotherapy@outlook.com

I will aim to respond to and resolve concerns appropriately.

You also have the right to raise a concern with the Information Commissioner's Office (ICO): www.ico.org.uk

21. Changes to this Privacy Notice

I may periodically review and update this Privacy Notice to reflect changes to my services, technology, legal requirements or professional obligations.

The most recent version will be published on my website.