Tonbridge Counselling Service (TCS) Privacy Statement
Adapted for Covid-19 Online Counselling

The following statement has been made in compliance with the General Data Protection Register May 2018 (GDPR: https://ico.org.uk) it is subject to change and updates


Who we are

We are a Counselling Service situated in River Walk, Tonbridge, Kent. TCS Board of Trustees has overall responsibility for the running of the charity and they support the Counselling Manager, Amanda Hedger, in leading the service and its day-to-day running. We have a team of freelance counsellors who see clients working under the guidance and policies of TCS. As of May 2020, we also operate an Online Counselling Service borne out of the need to function during the period of Covid-19. Enquiries are centralised and counsellors work from either their home or TCS office.

As you engage with our service, we will request information about you that enables us to carry out our service in a professional manner. You have a right to know how your information will be stored and processed. We are registered Data Controllers and Data Processors because of how we collect and use your data.

What information do we collect?

After the initial enquiry and telephone call, if we are able to proceed, we will send you; Information About Online Counselling, a copy of this Privacy Policy to sign and another form, Important Information About You. These documents can be sent to you via email or Royal Mail. They can be returned via our encrypted email service, Royal Mail or delivered to our offices in Tonbridge if this is accessible to you.

If an initial assessment is arranged, you will meet online with our Counselling Manager or another experienced member from our team who will ask you some questions and complete an Assessment Form of both general (name, contact details, date of birth) and more sensitive information. This helps us to decide if we are the right service for you. Details of the Assessment Form and Important Information About You form will be communicated by telephone to your assigned counsellor. If you go on to have counselling, your counsellor will keep anonymised notes.

Please note that if paying by cheque or bank transfer your name may appear on our bank statement. To avoid this happening, please use the code your counsellor gives you.

Why do we collect your information?

We collect this information to fulfil our contractual and professional obligations to you. The information, is helpful to us in four main ways: it aids our communication with you, it enables us to consider carefully if we are the right service for you and if so to link you with the most appropriate counsellor for you depending on expertise and availability, it enables us to pass information to the counsellor you will be working with. Keeping anonymised notes and printing any email counselling, are an important part of your counsellor working ethically and professionally with you. We do not engage in counselling without your permission to keep these notes.

What do we do with your information?

Forms are stored in a locked filing cabinet in the counsellor’s home office. Once counselling commences your counsellor will keep anonymised notes which are stored separately to any other data. If you choose email counselling, emails will be printed and stored in your notes without names or email addresses.

In addition to your counsellor keeping data, our Office Administrator, Jill Gibbs may also need to email you or contact you by telephone to discuss your appointment or arrange payment. At the end of lockdown all forms will be returned to Tonbridge Counselling Service and stored securely at the above address.

TCS or your counsellor may have to contact designated outside agencies such as The Police, Social Services, GP or other if an issue is in direct conflict with our legal or ethical obligations as a counselling agency. These are explained in the Client/Counsellor Agreement. Safeguarding Issues will be brought to the attention of the Safeguarding Officers for TCS who are Amanda Hedger and Jill Gibbs.

Online Security

We want to make sure that your data is protected to prevent unauthorised access by a potential hacker. We have taken measures to encrypt our email messages as they are sent from us. We strongly advise you to check that your Wi-Fi is secure, ensure your devices are password protected and not left where other people can access them. We strongly advise that you use a personal computer and/or email account and that your device has anti-virus software, firewall protection and encryption. We strongly advise you to use a private Wi-Fi connection and not a public one. We cannot be held responsible for any security breaches outside our control.

For video counselling we use the platform Zoom because this is encrypted and supported by our professional bodies. Telephone counselling sessions are conducted from a private and confidential environment that ensures we are not overheard.

How long do we keep data for?

If you decide not to proceed with TCS after the initial assessment appointment, please let us know. The Assessment Form will then be securely destroyed. If your start is delayed, we keep the form for 2 months after which it will be destroyed. Should you wish to approach us for counselling after the 2 month period the initial appointment would need to be repeated.

Whilst working with you we need to keep information to fulfil our contractual commitment to you, we also have a legitimate interest to keep information for up to 5 years in relation to client information that might be needed by a court of law.

What are your rights?

You have the right to see the information we keep and make any corrections if it is not accurate. You have the right to ask that your data be destroyed, however, should you withdraw consent we will keep minimum details that identify you for 5 years and erase all other information. You have the right to ask that your data be transferred to other services. You have the right to restrict processing where the data is inaccurate, the processing is unlawful, or the Data Controller no longer needs the information. We will never use your client data for marketing.

You have the right to complain. If you are unhappy with your experience at TCS and you feel able to, please discuss this with your counsellor in the first instance. Failing that, contact the Counselling Manager, Amanda Hedger in writing, who will address your complaint and respond within a reasonable time. TCS also adheres to the BACP (British Association of Counselling and Psychotherapy) Ethical Framework and the ACC (Association of Christian Counsellors). Details of how to make a formal complaint can be found on their respective websites. If your complaint concerns how your data has been processed please contact the ICO (information Commissioners Office). Website links can be found at the bottom of this document.

Your consent and our contractual rights

By signing this form, you are giving consent to us collecting your data. At the end of counselling you have a further opportunity to withdraw consent to keep your data. Should you decide to withdraw your consent at this stage TCS will still have a legal and legitimate interest to keep records that identify you should there be a case brought in a court and will keep minimum data in order to do this.

If you have any difficulty understanding this document or have any questions, please email our Counselling Manager, Amanda Hedger info@tonbridgecounsellingservice.co.uk or telephone 01732 605046.

BACP (British Association of Counselling and Psychotherapy) Ethical Framework www.bacp.co.uk

ACC (Association of Christian Counsellors) www.acc-uk.org

General Data Protection Regulation May 2018 (GDPR: https://ico.org.uk). Our ICO registration number is ZA065319.

Professional counsellors and counselling services in Tonbridge, Kent
Registered Charity 1155690
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