Vicki Wood (Attachment Focus) takes the collection and storage of your information very seriously and complies with both the Data Protection Act 1998, and the European General Data Protection Regulations (GDPR) 2018.
What information do I collect?
As part of the direct work process, I will collect information from you. This will include details such as names, address, contact details, and the network around you. I will also collect information relating to emotional health and wellbeing. I will take notes or undertake video recordings during our sessions to help me plan our work.
Some of the information I may collect is classified as sensitive personal data. The reasons for collecting this information are ‘legitimate interest’. Please see the ICO website for further explanation of this.
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:
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Your consent. You are able to remove your consent at any time. You can do this by contacting: vicki@attachmentfocus.com
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We have a contractual obligation
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We have a vital interest
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We have a legitimate interest
This information will allow me to provide a service to you, and to help me ensure the quality of my service. I will not use your information for marketing purposes.
What information will I share?
In accordance with good practice guidance I will undertake peer supervision, and supervision by an accredited DDP/Theraplay® supervisor for any work undertaken. They are also bound by regulatory body rules of confidentiality. I may discuss details of our work with my Supervisors but will not disclose personal data (e.g. names). The discussions we have within our sessions remain confidential to myself and my Supervisors unless I am required to break confidentiality for legal or safeguarding reasons. If I feel that there are any concerns relating to safeguarding, I may have to break confidentiality and inform the relevant parties. This may be statutory bodies e.g. Social Services. If possible, I will discuss this with you before sharing the information. I will also need to share information in any summary reports requested by the commissioning body. Again, I will discuss this with you.
How is information stored?
I will keep information securely in accordance with ICO guidelines. Storage may be electronic or hard copy. Where possible Attachment Focus aims to be paper-free. Any hard copies will be stored in a locked filing cabinet. The files may be transferred to sessions by car. Electronic information will be stored on a password protected computer. Emails will be sent and stored via a password protected account in a GDPR compliant Egress email account. I will not store your number on my mobile phone although I will keep text messages whilst you are receiving a service. Text messages will be used primarily to confirm appointments. Please do not send any sensitive information via text message.
I may communicate with you by mobile phone or email. If I send reports electronically, they will be password protected via an Egress account.
How long will information be kept for & what rights do I have?
Upon completion of the intervention, any reports will be passed to the commissioning agency, and electronic records (including contact details) will then be destroyed after one month.
Under data protection law you have rights including:
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Right of access - You have the right to request access to copies of your personal data.
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Right to rectification - You have the right to request the correction or deletion of information that you believe to be inaccurate.
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Right to erasure – You have the right to ask me to erase your personal information in certain circumstances.
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Right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances
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Right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
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Right to data portability – You have the right to ask that I transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond.
If you have any further questions or concerns, please contact me on: vicki@attachmentfocus.com
or the ICO at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113