The information below outlines the GDPR Privacy and Data protection policies and complaints procedure for therapist Patrizzia Ciaccio Therapist. For website Cookie and Privacy policies please click on the cookie pop-up window and Data Protection and Privacy Policy, the same information can be found on the GDPR tab on the website footer.
PRIVACY POLICY
Scope of the policy
This privacy policy applies to the work of therapist Patrizzia Ciaccio (hereafter referred to as ‘PC’). The policy sets out how PC deals with your ‘personal information’ gathered; that is, information that could identify, or is related to the identity of, an individual.
This policy should be read in tandem with PC’s Data Protection Policy.
What personal information does PC collect?
To treat you, PC will ask you to provide certain information. This includes:
- Name
- Gender
- Date of birth
- Home address
- Email address
- Telephone number
- Emergency contact details
- Medical history and health information
- Information relating to your consultations and treatment
- Correspondence between us
- Payment and appointment information.
How does PC collect this personal information?
All the information collected is obtained directly from you via an initial discovery call or email enquiry, subsequent telephone calls and your therapeutic consultation. At the point at which you provide your personal information, PC will also request that you provide consent for her to store and use your data. Your consent is required to ensure her compliance with data protection legislation. This consent applies to first contact, emails, telephone calls and consultations.
How does PC use this personal information?
PC collects information so that she can:
- Assess your mental and emotional needs.
- Provide treatment.
- Maintain accurate clinical records.
- Arrange and manage appointments.
- Communicate with you regarding your treatment.
- Meet my professional, ethical and legal obligations.
Where required, she will also rely upon your consent for specific activities.
With whom does PC share your personal information?
Your information will be treated as confidential. PC may share relevant information where appropriate with:
- Other healthcare professionals involved in your care.
- Clinical supervisors.
- Professional advisers.
- Regulatory, legal or public authorities where required by law.
- Service providers who support the operation of my practice.
Information will only be shared where there is a lawful basis to do so.
Clinical Supervision
As part of maintaining professional standards, PC may discuss cases with a clinical supervisor.
Where possible, identifying information will be minimised and only information relevant to the supervision process will be shared.
All supervisors are expected to maintain appropriate standards of confidentiality.
Online Consultations and Digital Communication
Where consultations take place online, or where email and other digital communication methods are used, reasonable steps will be taken to protect the security and confidentiality of your information.
However, no electronic communication system can be guaranteed to be completely secure.
AI and Digital Systems
PC may use secure digital tools to assist with administrative tasks, record management or communication.
Where AI or digital systems are used, PC remains responsible for the accuracy, confidentiality and security of your information.
Any records generated through such systems will be reviewed and verified before being relied upon or retained.
How long does PC keep your personal information?
Discovery call information, namely your name, phone, email address, and the reason for contact will be collected and stored electronically or in paper format. If you decide not to receive treatment or if you are still contemplating whether you want to receive treatment, your information will be held for up to 6 months and then your health information will be destroyed. Your name and contact details will held as a record of point of enquiry and date of destruction of health information in order to be compliant with GDPR privacy regulations.
Patient records are retained in accordance with Code of Ethics for the British Association for Counselling and Psychotherapy (BACP) and British Association for Behavioural and Cognitive Psychotherapies (BABCP) and any applicable legal, professional or regulatory requirements.
Adult records will be retained for at least seven years following your last consultation. After the relevant retention period has expired, records will be securely destroyed or deleted.
How your information can be updated or corrected
To ensure that PC has accurate and up-to-date information, you need to inform her of any changes you believe she should make to the personal information she holds. You can do this by contacting her by any of the methods previously described.
Under data protection legislation, you have the right to inspect the personal information PC holds about you. You can make a request to do so by contacting her and she will endeavour to respond within 14 working days.
How does PC store your personal information?
PC takes reasonable steps to protect personal information against loss, misuse, unauthorised access, disclosure or alteration.
Patient files are paper-based and are held securely within a locked filing cabinet within a locked room to protect your personal information against loss or theft, as well as unauthorised access, disclosure, copying, use, or modification. Information may also be stored in secure, password protected, electronic systems, encrypted devices or secure cloud-based services.
Your email address, if you have one, is held securely on the servers of PC’s email providers and on your paper-based file.
Your Rights
Under data protection law, you have a number of rights, which may include:
- The right to be informed about how your information is used.
- The right to request access to your personal information.
- The right to request correction of inaccurate information.
- The right to object to certain types of processing.
- The right to request erasure of information in certain circumstances.
- The right to raise a concern or complaint.
Some of these rights are subject to legal and professional obligations that may require records to be retained.
Changes to this policy
This policy may change from time to time. If PC makes any material changes, she will make you aware of them.
Contact
If you have any queries about this policy, need it in an alternative format, or have any complaints about PC’s privacy practices, please contact her:
Patrizzia Ciaccio
07788613039
Policy review date – June 2028
Data Protection Complaints
Purpose
PC is committed to providing a professional, respectful and high-quality service. If you are dissatisfied with any aspect of the service she provides, PC encourages you to raise your concerns so they can be considered fairly and, where possible, resolved promptly.
Informal Resolution
In the first instance, PC will encourage you to discuss any concerns directly with her.
Many concerns can be resolved quickly through discussion and clarification, without the need for a formal complaint.
Making a formal complaint
If a concern cannot be resolved informally, you may make a formal complaint.
Complaints should be submitted in writing by email or post and should include:
- Your name and contact details
- A description of your complaint
- Relevant dates and circumstances
- Any supporting information you wish to provide
- The outcome you are seeking
Acknowledgement
PC will normally acknowledge receipt of your complaint within 7 working days.
Investigation and response
PC will investigate your complaint fairly, objectively and confidentially.
A written response will normally be provided within 28 days of acknowledgement.
Where additional time is required, PC will explain the reason for the delay and provide and updated time frame.
Further Action
If you remain dissatisfied after PC has responded to your complaint, or if are unable to resolve the matter, you may seek further guidance from her professional bodies or therapy memberships, listed below, in accordance with their published complaints procedures.
British Association for Counselling and Psychotherapy
Head office, BACP House, 15 St John’s Business Park, Lutterworth, Leicestershire LE17 4HB7
Telephone: 01455 883300
Email:
British Association for Behavioural and Cognitive Psychotherapies
Head Office, BABCP, Imperial House, Hornby Street, Bury, BL9 5BN
Telephone: 0330 320 0851
Email:
If you remain dissatisfied, you have the right to complain to the Information Commissioner's Office (ICO) by visiting https://ico.org.uk/make-a-complaint/
Legal Rights
Nothing in this procedure affects your statutory or legal rights.
Changes to this policy
This policy may change from time to time. If PC makes any material changes, she will make you aware of them.
Contact
If you have any queries about this policy, need it in an alternative format, or have any complaints about my privacy practices, please contact me:
Patrizzia Ciaccio
07788613039
Policy review date: June 2028
DATA PROTECTION POLICY
Scope of the policy
This policy applies to the work of therapist Patrizzia Ciaccio (hereafter referred to as ‘PC’). The policy sets out the requirements that PC has in order to gather personal information for professional purposes. The policy details how personal information will be gathered, stored and managed in line with the UK General Data Protection Regulation (UK GDPR), tailored by the Data Protection Act 2018. The policy is reviewed on an ongoing basis to ensure that it is compliant. This policy should be read in tandem with PC’s Privacy Policy.
Why this policy exists
This data protection policy ensures that PC:
- complies with data protection law and follows good practice
- protects the rights of patients
- is open about how she stores and processes patients’ data
- protects herself from the risks of a data breach
Data protection principles
The General Data Protection Regulation identifies 8 data protection principles.
Principle 1 - Personal data shall be processed lawfully, fairly and in a transparent manner
Principle 2 - Personal data can only be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
Principle 3 - The collection of personal data must be adequate, relevant and limited to what is necessary compared to the purpose(s) data is collected for.
Principle 4 – Personal data held should be accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that are inaccurate are erased or rectified without delay.
Principle 5 – Personal data which is kept in a form which permits identification of individuals shall not be kept for longer than is necessary.
Principle 6 - Personal data must be processed in accordance with the individuals’ rights.
Principle 7 - Personal data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Principle 8 - Personal data cannot be transferred to a country or territory outside the European Union unless that country or territory ensures an adequate level of protection for the rights and freedoms of individuals in relation to the processing of personal data.
Certain of these principles are expanded upon in the sections that follow.
Lawful, fair and transparent data processing
PC requests personal information from patients and potential patients for the purpose of consulting with them and providing them with advice and guidance on treatments. Please refer to the policies held in main menu labelled ‘Data protection privacy’ on PC’s websites https://www.cbt4health.co.uk and https://www.counselling4health.co.uk for a full explanation of why the information is being requested and what the information will be used for. Patients should be asked to provide consent for their data to be held and a record of this consent along with patient information will be securely held. Patients will be informed that they can, at any time, remove their consent and will be informed as to what to do should they wish to do so.
Processed for Specified, Explicit and Legitimate Purposes
Patients will be informed how their information will be used and PC will seek to ensure that patients’ information is not used inappropriately. Appropriate use of information provided by patients includes:
- Communicating with patients to make, change or cancel consultations
- Assessing the conditions and issues reported by patients and devising and prescribing relevant treatment.
PC will ensure that patients’ information is managed in such a way as to not infringe an individual’s rights which include:
- The right to be informed
- The right of access
- The right to rectification
- The right to restrict processing
- The right to data portability
- The right to object.
Adequate, Relevant and Limited Data Processing
PC’s patients will only be asked to provide information that is relevant to support consultations and prescription. This includes:
- Name
- Date of birth
- Gender
- Postal address
- Email address
- Telephone number
- Emergency contact details
- Medical history and health information
- Information relating to your consultations and treatment
- Correspondence between us
- Payment and appointment information.
Where additional information may be required, this will be obtained with the specific consent of the patient who will be informed as to why this information is required and the purpose for which it will be used.
There may be occasional instances where a patient’s information needs to be shared with a third party due to an accident or incident involving statutory authorities. Where it is in the best interests of the patient or of PC, in these instances where PC has a substantiated concern then consent does not have to be sought from the individual.
Accuracy of Data and Keeping Data up to Date
PC has a responsibility to ensure that patients’ information is kept up to date. Patients will be required to let PC know if any of their personal information changes.
Accountability and Governance
PC is responsible for ensuring that her practice remains compliant with data protection requirements and can provide evidence that it has. For this purpose, those from whom data is required will be asked to provide written consent. The evidence of this consent will then be securely held as evidence of compliance.
Secure Processing
PC has a responsibility to ensure that data is both securely held and processed. This includes:
- using strong passwords for information held within computer systems
- restricting access to computer and paper-based files
- using password protection on laptops and PCs that contain or access personal information
- using password protection or secure cloud systems
- providing adequate virus-protection and firewall software to secure computer-based systems.
Subject Access Request
PC’s patients are entitled to request access to the information that is held by PC. The request needs to be received in the form of a written request to PC.
On receipt of the request, the request will be formally acknowledged and dealt with within 14 days unless there are exceptional circumstances as to why the request cannot be granted. PC will provide a written response detailing all information held on the individual. A record shall be kept of the date of the request and the date of the response.
Data Breach Notification
Were a data breach to occur, action shall be taken to minimise the harm. PC will inform any patients where she believes their personal information has been compromised. Where necessary, the Information Commissioner's Office will be notified.
If a patient contacts PC to say that they feel that there has been a breach by PC, she will ask the patient to provide an outline of their concerns. If the initial contact is by telephone, PC will ask the patient to follow this up with an email or a letter detailing their concern. The concern will then be investigated fully and a response made to the patient. Breach matters will be subject to a full investigation; records will be kept and all those involved notified of the outcome. In the unlikely event that a Patient is unhappy with PC’s response to any complaint regarding a Data Breach they may contact the ICO at:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Fax: 01625 524510
Policy review date: June 2028
To find out how my services may help you please contact me:
Telephone: 07788613039
Email:
