Purpose of privacy notice
The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR). This legislation will replace current data privacy law, giving more rights to you as an individual and more obligations to organisations holding your personal data.
One of the rights is a right to be informed, which means we must give you even more information than we do now about the way in which we use, share and store your personal information.
This means that we will be publishing a new privacy notice, so you can access this information, along with information about the increased rights you have in relation to the information we hold on you and the legal basis on which we are using it.
This new privacy notice comes into effect and will be published on our website on 25 May 2018.
Who are we?
AKORDIA is the data controller (email@example.com). This means we decide how your personal data is processed and for what purposes. ARKORDIA is a charity in Scotland (SC 039951)
Whose information does this privacy notice apply to?
This privacy notice applies to information we collect from:
- prospective patients/clients,
- former patients/clients
- Friends and associated organisations of ARKORDIA
What is personal data?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. Examples of personal data we may hold about you include your contact and appointment details.
Special category data is a sub-category of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Examples of special category data we may hold about you include your patient notes.
How do we process your personal data?
We comply with our obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We use your personal data for the purposes set out below.
- We use your name, address, telephone number and email address to make and rearrange appointments. We are unable to send or receive encrypted emails, so you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
- We use your name, address, telephone number and email address, only if we have your explicit consent, to send you marketing materials. We are unable to send or receive encrypted emails so you should be aware that any emails we send or receive may not be protected in transit. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send us is within the bounds of the law.
- We keep a permanent attendance register which records all appointments for clients/patients attending sessions to keep a record of when you were treated for tax purposes and charity governance purposes and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to our regulatory body (COSCA or our individual therapists’ governing body such as BACP or UKCP)
- We may use your date of birth to help identify patients with the same name to avoid mistakes being made as to safe and appropriate treatment, for identification purposes if referring a patient to another health practitioner, and for identification purposes if writing to a registered medical practitioner so that they correctly identify the patient.
- We use your presenting issues and situation and use any relevant medical and family history reported by you for the purposes of formulating treatment planning.
- We use your GP’s name and address in case we need to contact your GP including in an emergency.
- We keep a record of and refer to session notes which will summarise to a greater or lesser extent, what was covered in counselling/psychotherapy sessions, this may be a few key words or a paragraph and this information is kept securely and destroyed securely after three years.
- We record any decisions made in conjunction with you to help you to receive the most appropriate treatment and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
- We keep accident records for any patients, visitors or staff who are involved in accidents at our clinic in accordance with UK Health and Safety legislation including the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) to comply with the law and to secure evidence in the event of criminal proceedings, civil litigation, an insurance claim or complaint.
- Where relevant we maintain records of the patient’s consent to treatment, or the consent of their next-of-kin in order to be able to prove that the patient (and/or parent/guardian/next of kin) has given informed consent to treatment to secure evidence in the event of a civil claim, criminal prosecution, insurance claim or complaint.
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We usually have to disclose the complainant’s identity to whoever the complaint is about. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis. We may need to provide personal information collected and processed in relation to complaints to the British Acupuncture Council or our insurance company.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
We maintain and use records of subscribers to our newsletters, only with their consent, for marketing purposes.
We use a third-party service, (Nativespace.net), to host our website and publish our blog through WordPress.com (currently not a feature of this business.)
Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared:
- with named third parties with your explicit consent;
- with the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which we are subject e.g. a court order;
- with your doctor or the police if necessary to protect yours or another person’s life;
- with the police or a local authority for the purpose of safeguarding children or vulnerable adults; or
- with our regulatory body, COSCA, or individual therapists’ insurance company in the event of a complaint or insurance claim being brought against me; or
- our solicitor in the event of any investigation or legal proceedings being brought against me.
For further details about the situations when information about you might be shared please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/personal-information/sharing-my-info/
job applicants, current and former employees and trustees
We are the data controller for the information job applicants provide during the process.
? All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.
? We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us whether the information is in electronic or physical format.
? We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.
? We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.
? The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.
? We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for.
? We shortlist applications for interview.
If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability. Additionally we are members of the PVG scheme and will employ you on the basis of your being on the PVG register as a volunteer counsellor (where applicable)
You will therefore be required to provide:
? Proof of your identity – you will be asked to attend our clinic with original documents, we will take copies.
? Proof of your qualifications – you will be asked to attend our clinic with original documents, we will take copies.
? You will be asked to complete a criminal records declaration to declare any unspent convictions.
? We will contact your referees, using the details you provide in your application, directly to obtain references.
? We may also ask for emergency contact details – so we know who to contact in case you have an emergency at work.
If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 3 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any references.
If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the recruitment process.
Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the recruitment process.
All of the information gathered during the application process is taken into account to make final recruitment decisions.
For further details about the situations when information about you might be shared please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/personal-information/sharing-my-info/
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary.
We keep patient records for a period of 3 years
We keep your data up to date with periodic emails or through personal contact. All data is deleted after a reasonable time, generally, all contact details are kept as long as it is required to keep notes, in other words, 3 years. Emails and texts will be deleted after their relevance ceases. All paper records are destroyed by commercial secure shredding facilities.
Data is kept up to date on a regular basis; some is held on our organisation’s computer which is kept securely, and password protected. Paper records of consent and sessional information is held securely and updated individually after each client/patient has attended a session
At any time, you may request that changes are made to your contact details.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have certain rights with respect to your personal data as set out below
? The right to request a copy of your personal data which we hold about you.
? The right to request that we correct any personal data if it is found to be inaccurate or out of date.
? The right to request your personal data is erased where it is no longer necessary for us to retain such data.
? The right to withdraw your consent to the processing at any time. This right does not apply where we are processing information using a lawful purpose other than consent.
? The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [This right only applies where the processing is based on consent or is necessary for the performance of a contract with you and in either case the we are processing the data by automated means].
? The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
? The right to object to the processing of personal data, (where applicable) [This right only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics].
? The right to be informed if your data is lost. We shall also inform the Information Commissioner’s Office in accordance with the time limits in the GDPR.
? The right to lodge a complaint with the Information Commissioner’s Office.
For further details about these rights please see the Information Commissioner’s website at https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
To exercise all relevant rights, queries of complaints please in the first instance contact us at firstname.lastname@example.org or through the contact form on this website
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
This report represents an ongoing project to keep out data management compliant, relevant and up to date
About ARKORDIA; an article written for COSCA in 2013
ARKORDIA: a cooperative model of counselling provision.
Arkordia has been formed to provide a counselling and psychotherapy service in the Edinburgh and Lothians area, which is affordable and accessible to individuals, couples or families.
The name Arkordia has its roots in the Greek word “kardia” meaning heart, also from the word “ark” which implies shelter and refuge. The combination of these two words embraced the philosophy of the founding members of Arkordia, and their intentions, that the psychotherapy, counselling and creative therapies offered by us would be from the heart, providing a safe place for people to grow and become themselves. Interestingly it also sounds like accord which means in one of its definitions, that I read in the shorter Oxford English Dictionary “To bring heart to heart” “To cause to agree” “to be in harmony with”.
Arkordia grew out of the closure of No. 21 counselling service in Edinburgh in 2006; a small group, who were volunteer counsellors plus one of the originally paid staff at No. 21 began to meet together in the early part of 2007 to begin the process of designing and formulating our service. Out of those early discussions we attracted a substantial grant from “Awards for All” to employ a consultant to provide evidence for the need for such an agency and establish a development plan for a 5 year period. On this basis, we registered as a charity and formulated our memorandum and articles of association as a charitable company. Our evolving philosophy and values were deeply embedded in these formal documents and established a modus-operandi of a cooperative, non-hierarchical management in which all those involved in the organising and delivery of the service would have equal standing.
There was a long and sometimes painful gestation period. The longest and still ongoing debate concerning payment of therapists remains but at present we are now a group gathering round the dual task of providing a counselling service through volunteer (unpaid) counsellors on a cooperative basis for those with generally small means. We reveled in making something from the roots up but the calling to be therapists in the service of a good cause was necessarily held up while this work carried on. We are not necessarily all skilled in the tasks of fund raising, taking minutes (though we now have a paid administrator for certain tasks which is a Godsend) filling in forms for disclosure Scotland and collecting statistics to support fundraising efforts. The practical task of meeting, organising and deciding was at times frustrating while also feeling necessary for us all. We sometimes got confused over respect for one another and the necessity of meeting the task we had set ourselves. The planning of meeting times ahead rather than only the next one ahead became a matter of frustration. The impotence we felt over the slowness of recruiting therapists was palpable at times as we attempted to incorporate some of the fundamental core values of the therapeutic process; acceptance, valuing, empathic understanding, choice, shared power and openness in our dealings with each other. But it is through this kind of process that we have built trust connection and challenge in our interaction with each other. We meet on a regular basis for business meeting and in a peer group supervisory mode for evaluation and review. It seems, that for the present, we are likely to remain quite small but the transition from an organisation setting itself up to one that is up and running has been made.
It is a fundamental tenet of our group that we bring the same respect and horizontal way of dealing with one another that we bring to our work with clients so it is worth reflecting what is meant by a cooperative. For example the shared task we have at present is to reduce our client waiting list. Within a conventional hierarchical organisation the decision may be taken to reduce contact time with clients to say six sessions, (So far our work with an individual client can be open ended) or to recruit more therapists. This decision would be taken by a manager or director and the staff would set about complying with it. Within a cooperative way of working such decisions are taken together. This implies and asks for a willingness to wait on others, a discussion and a teasing out of the concerns and always an attempt to listen to the others voice. Decisions are made from the basis of a consensus of understanding. You can hear, in this way of expressing it, how close it is to the understanding of what we are required to do within our client work. Our authority is exerted as an extension of the combined understanding of being a part of the group in that moment and of our own personal understanding of the goals of the organisation but, to quote Randy Schutt’s paper:
“Consensus is a process for deciding what is best for a group. The final decision is often not the first preference of any individual in the group, and many may not even like the final result. But it is a decision to which they all consent because they know it is the best one for the group”.
So there is a willingness to let go ones own preference in favour of movement to the essential goal. You might say, ‘but do not hierarchical organisations do this also?’ The difference is, at root, a matter of philosophy. The decision taken within a cooperative group rests on the belief in equality and parity of influence being made visible. To coin the phrase we are “equal before God” but within a cooperative group more effort is demanded than is found in a hierarchical organisational structure, to ensure that that this is manifested as a lived process. The resort to diktat is impossible within a cooperative, which does not mean that the power of individual personalities cannot sway decision-making in certain directions but it is always held in check as long as the essential idea of cooperation is continuously experienced as a shared as well as an individual responsibility.
In this way we incorporate those fundamental and core values of the therapeutic process mentioned earlier. You may say ‘But is not this way of working inefficient in time and energy?’ Where there is a lot of contention and with that mistrust also then as with any organisation the arguments can become circular and unproductive and even vituperative.
Randy Schutt again;
“Many groups feel that they must allow every person in the group to fully discuss every possible perspective on every issue. When there is little trust in a group of people, this may be justified. But consensus does not require this. In a cooperative, trusting group it is possible to allow individuals or committees to make most decisions with little or no discussion in the larger group. When the group is pressed for time, quick, though less ideal decisions, can also be tolerated”.
At the conclusion of our lengthy period of investigation and discussion we were anxious to proceed as soon as possible. Our development plan was based on raising funds to pay counsellors and to secure premises but it was also evident that raising the level of funding required, in the current and persisting economic climate, would make that difficult, particularly if we were to preserve an affordable and accessible service. As we had a surplus of funding from the Awards for All grant, we were able to renegotiate the use of it to support a pilot year and, with a further grant from Edinburgh Volunteer Organisation Trust (EVOT) we covered ongoing expense for administration and publicity but this was on the basis of operating as volunteer practitioners. The conclusions we drew from our pilot year experiences was a need for our service, that our approach, in terms of management and practice was viable and that based on voluntary effort it was rewarding and successful. As consequence of this we have come to value more fully the idea of volunteering as a core part of our groups understanding of itself.
David Pilgrim maintains that psychotherapy: (It) works at its best in a voluntary and individual contract… (p121).
We have extended this volunteering principle further, inviting clients to make anegotiated level of donation; what Natiello calls a “Self Selected Fee” and identifies this as :
….(a) “philisophical stance that paves the way for more equality between my client and me. Asking clients to choose a fee that is appropriate for them, based on their ability to pay, established their responsibility to the relationship and their right to make decisions about their own lives at the outset of therapy”, (p39)
We set a scale of £5 to £40 anticipating that there would be a range of offerings which would average out sufficiently to cover basic costs of administration and rental of premises. In 2010, our pilot year , Arkordia worked with 23 clients and established a waiting list of a further 23 potential clients. At this point the contact work and the administrative procedures were carried out by what we call the Operational Management Group all on a voluntary basis. Two of us gave many, many hours of time to this process but an average of the 6 of us gave upwards of 40/45 hours in the year including seeing clients.
We have established our practice and procedures more fully now. Arrangements are that potential clients ring a dedicated number indicating their wish to use the service. They leave their name and contact details on an answer phone. Our administrator returns their call within 24hrs when she takes further details and preferences. These details are held securely in an online record system accessed later by practitioners to arrange sessions. Individual client work notes and records are kept in a dedicated and locked filing cabinet in the venue from which we work. There have been concerns about potential users being put off by the telephone access system but by and large this is clearly not the case. Of course the generation of a long waiting list remains worrying and has led to two recruitment drive for more practitioners. One remarkable observation in that first year was that the ongoing administrative expenses were covered entirely by the client donations. We have been and are in an ongoing debate about offering training places to students.
As we progress into our fourth year we are recruiting more colleagues which may include students who are well on in their training. We are developing a unique organisation that offers its members a rich working experience that augurs well for the experience of our clients also. We have a valuable and unusual profile which we are sure has a wider appeal than we have been able to establish so far.
The poetic image of Noah’s ark comes to mind, a picture of a still slightly cumbersome craft full of animals, birds, insects, fish and of course Noah’s huge family. It has arrived on the top of Mount Ararat, the dove has returned. The waters have receded. We can tether our craft to the tree not in our case on Mount Ararat (Does it have trees?) but the more prosaic but completely real and generous establishment of the Southside Counselling Centre.