PRIVACY POLICY 

Introduction 

I am fully committed to ensuring that your privacy is protected. I endeavour to abide by the ethical frameworks of the professional organisations to which I belong, including the British Association for Counsellors and Psychotherapists (BACP) and the British Psychological Society (BPS). 

Your privacy is very important to me and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to me. I adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003. 

I am happy to chat through any questions you might have about my data protection policy and you can contact me via email info@kayatzcounselling.ch or by phone +41(0)79 817 0097.

‘Data controller’ is the term used to describe the person/ organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is me. 

I am registered with the Handelsregister des Kantons Zürich CHE-141.390.791.

My lawful basis for holding and using your personal information 

The GDPR states that I must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which I am processing your data. I have explained these below: 

  • If you have had counselling and therapy with me and it has now ended, I will use legitimate interest as my lawful basis for holding and using your personal information.

  • If you are currently having counselling and therapy or if you are in contact with me to consider it, I will process your personal data where it is necessary for the performance of our contract.

The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for me processing any special categories of personal information is that it is for provision of health treatment (in this case counselling) and necessary for a contract with a health professional (in this case, a contract between me and you).

Initial contact

When you contact me with an enquiry about my counselling services I will collect information to help me satisfy your enquiry. This will include your name and contact information, and the reason for contact. Alternatively, your GP or other health professional may send me your details when making a referral or a parent or trusted individual may give me your details when making an enquiry on your behalf. If you decide not to proceed I will ensure all your personal data is deleted within 30 days. If you would like me to delete this information sooner, just let me know. 

Third party privacy statement 

Your information does not get shared with anyone else within my private practice, as I manage my practice myself as am independent practitioner. If you are referred to me via WePractice they will treat your privacy according to their privacy statement. 

From the moment you get in touch with me I will never try to obtain information about you from any third party without your knowledge and consent, unless I am approached by a third party to contact you on your behalf, e.g., Employee Assistance Programme. 

I will never share your information with any third party – unless you have explicitly told me that you would like me to, in order to help you get good support or healthcare, or unless your referral to the service was made via a third party, such as a legal or insurance company, or a healthcare provider.

I am required to have regular supervision with another professional therapist as part of my ongoing BACP accreditation as a psychological counsellor and therapist.  I never disclose any personally identifying information about my clients within supervision.

There are only three lawful exceptions where I do not need your consent to share information to a third party: child protection, court order and risk to life. 

Sharing Information

  • I only liaise with House Doctors or GPs or other parties if this is deemed necessary and/or helpful. In instances of perceived risk to self or others, I will need to communicate with your House Doctor or General Practitioner (GP). I will discuss this with you in the first session.

  • If you wish me to be able to discuss your situation with another health care provider (e.g., a specialist, another psychologist, a previous therapist) or any other person (e.g., a school counsellor, your spouse), I will ask you to sign a release of information to allow this.

The lawful basis for processing your data

I only use information about you in ways that are core or legally essential for me to fulfil my role as an effective, safe, ethical and responsive psychological counsellor and therapist.

I never keep or use your information in non-essential ways. For example, I do not send newsletters or marketing campaigns without your explicit consent.

Under GDPR regulations 2018, I am what is known as the ‘data controller’ and also the ‘data processor’, and I have specific responsibilities and requirements, accompanying these roles to protect your privacy.

Disclaimer: Your role in protecting your own privacy

I make every effort to ensure that my clients’ personal information is held securely and to safeguard against unauthorised access, whether I receive it via my website, emails, text, over Zoom, Skype or phone or in person. 

At the same time, in agreeing to my privacy policy:

  • You acknowledge that the privacy of your communications and personal information can never be completely guaranteed when it is being transmitted over the internet.

  • You acknowledge and agree that you share information via the internet at your own risk.

  • You agree to take responsibility for your own role in safeguarding your data privacy in the email address you choose to use and whether or not you choose to password protect information you send to me.

My policy is to request that clients endeavour to take the following actions wherever possible:

  • To email me from an email address that does not have your full name in it

  • To only include your first name in any documents you send me

  • To password protect documents that you may send me

I obtain information from:

  • What you choose to share with me when you first contact me via my website’s contact form, or when you phone or email me to make an enquiry.
    what you choose to share with me – information you send me by email and over the phone (text or voice message)

  • Sessions we have together in person, face to face, or phone and online (Skype or Zoom)

  • Your health insurance company or healthcare provider, if relevant, and with your consent

Your privacy when you first get in touch:

  • I’ll only keep your contact information if I have the capacity to respond and be of help to you.

Visitors to my website 

My website’s contact form:

  • When you get in touch via my contact form, you decide and choose what information you wish to share with me.

  • Your information is not stored anywhere on my website platform. Your contact form goes directly through to me via email.

When someone visits my website, I use a third party service, Squarespace, to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. I do not make, and do not allow Squarespace to make, any attempt to find out the identities of those visiting my website. 

I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website. 

Analytics

This website is powered by Squarespace and it uses visitor data to work correctly.

This website collects personal data to power our site analytics, including:

  • Information about your browser, network, and device

  • Web pages you visited prior to coming to this website

  • Your IP address

This information may also include details about your use of this website, including:

  • Clicks

  • Internal links

  • Pages visited

  • Scrolling

  • Searches

  • Timestamps

We share this information with Squarespace, our website analytics provider, to learn about site traffic and activity.

Cookies

This website uses cookies and similar technologies, which are small files or pieces of text that download to a device when a visitor accesses a website or app. For information about viewing the cookies dropped on your device, visit The cookies Squarespace uses.

These functional and required cookies are always used, which allow Squarespace, our hosting platform, to securely serve this website to you.

These analytics and performance cookies are used on this website, as described below, only when you acknowledge our cookie banner. This website uses analytics and performance cookies to view site traffic, activity, and other data.

Visitor data

Forms:

When you submit information to this website via webform, we collect the data requested in the webform in order to track and respond to your submissions. No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me. 

Visitors:

This website is hosted by Squarespace. Squarespace collects personal data when you visit this website, including:

Information about your browser, network and device

Web pages you visited prior to coming to this website

Web pages you view while on this website

Your IP address

Squarespace needs the data to run this website, and to protect and improve its platform and services. Squarespace analyzes the data in a de-personalized form.

About your initial free phone consultation

The purpose of your initial free telephone consultation is for you to ask any questions about my approach, and for me to provide you with some information about the ways in which I can support and work with you, and to find out if our schedules are mutually workable. Having a simple overview of your current issues, and what you want from sessions, helps to ascertain if I am best placed to work with you.

Emailing each other 

After we have decided on an initial appointment, I will usually send you a confirmation email detailing the venue or online meeting details, fee and other relevant practicalities.

Social Media

I do not connect with clients on Social media such as Facebook and LinkedIn. In the interests of client privacy, I do not Google clients or follow them on Twitter. 

Leaving messages

Any device on which I receive written messages is secured with passcodes and, for some devices, fingerprint lock. Devices can be wiped remotely in case of loss or theft. Any client information will be coded in the address book as ‘Cl’ plus your initials. 

online sessions 

Skype and Zoom services have updated their privacy measures to ensure they are fully compliant with GDPR regulations 2018.

You are welcome to install Zoom as an option for online sessions, and each session can be set up with different passwords. 

sessions where we meet in person

The therapy and consultation rooms that I use, may have other clients in the waiting area. Every client is treated with discretion and discussions with me only take place inside the consultation rooms. 

what type of information do i collect about you?

I will collect the following personal information from you, if we decide to work together, because, as a registered healthcare practitioner, I would be reasonably expected to have this in case of an emergency:

Personal Information:

  • Your name and contact details

  • Who should be contacted in case of an emergency (e.g. next of kin)

  • House Doctor or General Practitioner address

sensitive information

Given the nature of healthcare related data, some of the information you may share with me is likely to be classified as sensitive. I’m legally required to take strong measures to protect your confidentiality with any of the following sensitive information that would be important for me to know in order to help you:

  • Your mental and physical health

  • Use of alcohol, prescribed and non prescribed drug use

  • Any current ongoing criminal offences or alleged offences

  • If you choose to share any information with me about your relationship or sexual history or orientation, your family, lifestyle, employment, religion or cultural background, this is also respected as ‘sensitive’.

what do i use your information for?

I may at times need to ask you about some of the above sensitive information with the specific purposes of ensuring that:

  • The service I provide to you is properly responsive to your specific circumstances and needs.

  • I make safe and effective clinical and therapeutic decisions

  • I respond to you in the most considerate way

  • We communicate openly with one another to make wise and appropriate decisions together in a teamwork approach

With regards personal and sensitive information, I don’t need to have a written record of everything you share with me.  I keep my note taking outside of sessions to a minimum, and encourage my clients to keep their own notes of useful ideas, insights and reflections. As they relate to you and your progress, it’s much more relevant and helpful that notes are written by you and stay in your possession.

There are of course some things that I must, legally, have a written record of, if it is in direct relation to your safety or the safety others, such as emergency contact information, or information related to suicide risk, child protection, domestic abuse, or other violent crime, or should I ever need to account for my clinical decisions and/or respond to complaints.

transparency of record keeping 

Records may comprise of:

  • the emails, reports, forms or letters you have decided to send or cc:ed to me

  • emails, reports, forms or letters I have sent or ccd to you to the email address of your choice

  • any information you have forwarded to me from a healthcare provider or insurance company
    any information I have received from a healthcare provider I will always show you if you have not already been ccd

  • any information I send to an insurance company or healthcare provider I will make sure you have a chance to read and rectify as appropriate before I send and, if a legal or risk issue has been identified:

  • risk assessment and risk management plan, and my clinical supervisor’s recommendations, which I will also share with you, unless it would increase a safety risk to do so.

I do not transport paper material with identifying information. 

I take steps to ensure that no one else can access your personal data without your specific consent. In the unlikely event of a data breach, I will report this to you. 

You are able to request copies of the data I hold about you. I will respond within 30 calendar days. There is no fee for this. 

After your counselling and therapy has ended, I will retain your data for ten years, in accordance with Swiss data protection laws. At that point your data will be destroyed/erased, to include all electronic communications. In certain circumstances, you may wish to have your personal data permanently erased sooner than this. This is known as the right to be forgotten. 

To allow me to process your personal data in the above-described ways, I will need a clear and specific statement of consent from you. 

some limits to confidentiality and sharing information:

There are some situations where confidentiality may have to be broken or I would be required to share your information with third parties, without your consent:

  • Court Order: If I am required to disclose data about you, under a Court Order for me to do so.

  • Child Protection: If I am concerned about the welfare of a child, i.e., where there are child protection issues relating to potential physical, mental, sexual abuse or serious neglect

  • Risk to self or others: Where there is an imminent risk of serious harm to yourself or harm or exploitation of others.

If you are seeking help and you are perpetrating a serious crime against someone, or you are actively suicidal, I am unable to protect your right to privacy, as I must take appropriate action to protect the rights of children and vulnerable adults if I believe they are at risk. In those instances, I will always follow local and national safeguarding policies and the BPS and BACP Standards of Conduct, Practice and Ethics.

If you are worried about your safety or the safety of someone else, it is very important that you get access to the right kind of help ASAP. In crisis or high risk situations, it may well be more suitable for you to prioritise getting linked up with a therapeutic team who specialise in crisis or high risk situations. I will do my best to get you linked up with the most relevant sources of help, as a sensible alternative to working with an independent practitioner like myself.

contact me if you have any questions

If you have any questions or concerns about how your data is processed or shared, please do not hesitate to contact me by emailing on info@kayatzcounselling.ch or on +41(0)79 817 0097.