Supervision Privacy Policy

How I manage information about supervisees

Introduction

This document sets out my supervision privacy policy, which applies to supervisees to whom I offer services. It sets out how I manage information about supervisees and how I comply with my obligations under the General Data Protection Regulation (GDPR) 2018 and as a registered, accredited member of the British Association for Counselling and Psychotherapy (BACP).

A hard-copy version of this document can be downloaded as a pdf document: to be added

I have a separate privacy policy for those using my web-site: web-privacy

and for those I see as counselling and coaching clients: client-privacy

Information I collect

When we first meet I ask you to complete a ‘Supervisee Information Form’. This provides me with your contact details and other relevant information. I may also ask you to update this information during our work together.

Beyond that, the information I hold on you will be the written notes I make during and after each of our sessions and any other information you give to me. Depending on what you tell me, this may include personal sensitive information about you and about the clients you work with, for example about physical and mental health, sexual life, racial or ethnic origin, religious or other beliefs, offences and alleged offences.

Storage of this information

I keep the ‘Supervisee Information Form’ in its paper form in a locked filing cabinet, to which no-one else has access other than in exceptional circumstances (see “Therapeutic Will” below).

I also transfer the information on that form into the cloud data-base system I use for recording all my client and supervision appointments. The system I use is called ‘Bac-Pac’ and is managed by a company called Mayden. If you want more information about how their security systems work you are welcome to ask me, or to contact Mayden directly at: support@mayden.co.uk

I keep written supervision notes in a locked filing cabinet.

If you email me I read the email, deal with it and then delete it. I may copy the content of the email into Bac-Pac if I feel it is relevant to our work to keep it.

If you give me any paper-based documents at any time I will either store those in a locked cabinet, scan them and store them on my client data-base or read them and dispose of them.

Sharing of your information

There are only four circumstances when I may share some of the information I hold about you with someone else:

1. I have supervision on all aspects of my practice, which I consider is essential to ensure that I do the best work I can and it is a requirement of the British Association of Counselling and Psychotherapy. My supervision is itself confidential and I undertake to safeguard your identity in that process. If you are concerned about being recognised in supervision I can explain how it works and to whom I go for supervision.
2. If I am concerned about your practice and consider that it may pose a risk to your clients, or to you, I will normally bring that to your attention and explore options with you. If I am not able to explore my concerns with you or, following our discussion I am not satisfied that my concerns have been or are going to be resolved in a timely manner, then I may contact one or more third party in order to minimise the risk of harm to you and others. The third party or parties would usually be your professional body, your training agency if you are a trainee and possibly your employer if the work I supervise you upon is within your employment. 
3. Under very rare circumstances, I may be required by law to pass on information to the relevant authorities. This is the case if I believe you are involved in or are planning an act of terrorism, are involved in drug trafficking or money laundering. It can also happen if a court requires me to pass over information I am holding about you or one of your clients.
4. Because you ask me to do so, or providing a report about your work to a third party is part of our working contract. Under those circumstances I will normally show you a draft for comment before I send any information about you to the third party. In the case of references, I will normally send you a copy of the reference I write.

Therapeutic Will

In the case of my death, or my becoming incapacitated for an extended period, your name and contact details will be shared with my Therapeutic Executor. This is so that you can be contacted to explain what has happened, if you are seeing me at the time. If it becomes clear that I will not be returning to practice, all the paper-based client records and the contents of my client record system would be destroyed/erased.

Erasing your information

On the advice of BACP, I keep my supervision notes for seven years after we have completed our work together, at which point they are destroyed/erased.

Your rights under GDPR

Under this legislation you currently have the following rights:

To be informed about what information I hold (this document).

To see the information I hold on you (free of charge for the initial request).

To rectify/correct any inaccurate or incomplete personal information.

To request that your personal information is erased/deleted/shredded. I can decline this request if the information is needed for me to practice lawfully or competently, or if there is another reason (for example a complaint or legal reason).

My devices

I do not store client information on either my computer or mobile phone. I do access my emails through both and texts through my mobile phone.

Registration with the Office of the Information Commissioner

I am registered with the Office of the Information Commissioner (OIC), registration reference number ZA080937. I will notify the OIC should a data breach occur in my systems.

If you are unhappy with how I have dealt with your information you may make a complaint to the OIC: www.ico.org.uk, phone: 0303 123 1113

If you are unsure about any aspect of this policy document, please contact me.

Steve Page/How I manage information about supervisees/version 1: 28th May 2018