Data and Disclosure Statement
Southville Clinic, 68 Coronation Road, Southville, Bristol. BS3 1AS
0117 325 1210
Enso Hypnotherapy Limited is a limited company, registered in England and Wales. Company Number 10943567
I, Barry Wharton am the Data Controller and Processor of Enso Hypnotherapy Limited.
Education and training:
- Institute of Biomedical Sciences Fellowship (University of Manchester)
- BA(Hons) Chemistry and Physics (Open University (First Class))
- Chartered Chemist (Royal Society of Chemistry)
- Chartered Scientist (The Science Council)
- Post Graduate Certificate in Education (University of Bristol)
- Certificate in Hypnotherapy and Psychotherapy (National College of Hypnosis and Psychotherapy)
- Bielby Award 2016 (National College of Hypnosis and Psychotherapy)
- Fellow of the Institute of Biomedical Science (Member No. 280666)
- Member of The National Society of Hypnosis, Psychotherapy and Mindfulness (Reg.No. 4431)
- Member of the National Council for Hypnotherapy (Reg.No. 7917)
- Member of the Complementary and Natural Health Care Council (Reg.No. 000005-I17)
- Member of The United Kingdom Council for Psychotherapy (Trainee membership 2011165433)
I adhere to the code of ethics of these professional bodies. If you are unhappy with my treatment of you, you may write to any of these.
My fees are £150 for a special single session smoking cessation therapy (1.5 hours) with a free follow-up within three months if required and £55 per session (normally 50 minutes) for all other issues.
I accept payment in cash, by cheque or debit/credit card. There is no additional charge for card payments.
Please note that 48 hours’ notice is required for cancellations or the full fee may be payable.
The basis on which I keep client data is that of “Legitimate Interests”. This means that the data is necessary for me to fulfil the contract that we have together (ie to provide therapy) and that it is data that you would reasonably expect me to hold and use.
The data I hold includes:
- Basic information such as name, email address, phone number
- Information that you give me as part of the work we do together
- Records of what interventions that I use (or potentially do not use) in our sessions
- Emails, texts and/or messages that are sent between us (see below)
- Information sent from any third party, eg GP, insurance company, EAP
- Audio recordings of sessions
Some of the information that you give me may fall under the definition of special category of data as defined by the General Data Protection Regulation. The condition for processing this special data is “processing is necessary for medical diagnosis, the provision of health care or treatment pursuant to contract with a health professional”. However, data on any criminal offences (including allegations, proceedings and convictions) is even more tightly controlled and so I need your specific consent in order to hold any such information.
Data is not shared with anyone, except possibly your GP (see GP info section below), and for any reasons covered by the Requirements for Disclosure section below. However, if you were to make a complaint about me to my professional body, I would be entitled to share your notes with any investigation procedures. My accountant will see bank, credit card and Paypal records which will contain any information that you submit when making payment. If you would like me to redact your identifiable data before sending to the accountants then please let me know.
The data is primarily used to enable me to provide therapy for you. It may also be used scientific research purposes and statistical purposes.
Details of where data is held:
- Any emails sent between us are held either on my computer’s hard drive or if archived, in Dropbox which is secure cloud based storage which is itself GDPR compliant.
- Any texts sent between us (See Social Media and Electronic Information section) are held on my smart phone which is password protected.
- Your notes are recorded electronically and are held either on my computer’s hard drive or if archived, in Dropbox which is secure cloud based storage which is itself GDPR compliant. My computer access is secure password protected.
- Credit card information is shredded as soon as processed.
- If you use Paypal or online banking then clearly these systems will hold your data. I will download from these systems for accounting purposes and the resulting spreadsheets are held in Dropbox. When sent to my accountants, they will be password protected.
- Audio recordings are held either on my computer’s hard drive or if archived, in Dropbox which is secure cloud based storage which is itself GDPR compliant.
Your data is kept for 7 years. The length of time is based on the stipulation of my insurer. After this time any paper records are shredded and computer records permanently deleted.
Enso Hypnotherapy takes the security of data seriously and as such:
- All data is held securely (see details of where data is held above)
- Any data transmitted is sent encrypted where possible
- For accounting purposes Excel spreadsheets are used
- I am not in control of data (including emails and texts) which you send me
- Apps such as Facebook routinely access any information held and this is beyond my control.
If there is any breach of data security Enso Hypnotherapy will give full details to the Information Commissioners Office and any person affected within 72 hours of the breach and do all possible to minimise any potential impact.
You have rights with regards to the data held:
- The right of access. I will provide you with all data I hold on you as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).
- The right to rectification. If any data I hold is incorrect, just let me know and I will correct it as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).
- The right to erasure. If you wish me to erase your data just let me know and I will delete any computer records and shred any paper records as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness). NB: data may be retained for scientific research, historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing but this would never include case notes or data such as address/email/phone
- The right to restrict processing. This would usually be a stop-gap measure before correction of any errors or before erasure
- The right to data portability. This might apply if you want your notes sent to another therapist for example, but it is likely that the easiest solution would come under the right to access, ie I would send the data to you.
- The right to object to:
- processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling). Enso Hypnotherapy does not engage in these things
- direct marketing. I do not currently use client data for marketing purposes and if this changes you can opt-out at any time.
- processing for purposes of scientific/historical research and statistics. For this, you must provide grounds for your objection.
- automated decision making and profiling. Enso Hypnotherapy does not engage in automated decision making or profiling
The keys to successful therapy
There has been a lot of research conducted to discover what makes therapy work and consistently the findings show that the key factor is the relationship that develops between therapist and client. The other most important thing is that the therapist adapts to the client’s characteristics, culture and preferences.
My commitment to you
All relationships are based on trust, and the therapeutic relationship is no different so I will always do my best to understand you and your issues without making any presumptions. Everyone is different and you are entitled to be you and to hold your views about the world. If I struggle to understand, I will ask. I will not judge you.
What you can talk about
It is common for clients to be worried about disclosing information, wondering if it is safe to do so. Some therapists ask lots of questions but I feel that is too intrusive so I offer you this list of some things (and there are others) which clients may have experienced and which can be discussed.
- Abuse: domestic, sexual, physical or emotional, past or present
- Self harm or suicidal thoughts/attempts
- Guilty secrets
- Problems with eating (eg binging or purging)
- Criminal convictions (see below for current criminal activity)
- Disturbing thoughts or wishes
- Sexual issues
- Anything not listed below!
Requirements for disclosure
Having given examples of all the things that you can discuss with me, it’s important that you know that the law may forbid our normal confidentiality in the following circumstances:
- If I become aware, or have good reason to suspect, that you have knowledge of:
- A past or future incident/situation that may be dangerous or harmful to a child, you or another adult, and that is not known to the relevant authorities.
- Future or past criminal activity that has not been resolved in law. This means any criminal activity, of which the relevant authorities are either unaware or a case they know about which they consider not to be closed (provided you do not present information in therapy which would reasonably re-open the case). This does not include parking or traffic offences unless there is intent, by you or anyone else, to cause danger to yourself or others, or that it is deemed to be a “serious offence”. For our purposes a serious offence is something for which you could be imprisoned and for which the sentence (not necessarily imprisonment) hasn’t yet been served.
- In these circumstances I will work with you to see if we can work together to make appropriate disclosures.
- It is also compulsory to report terrorism, potential radicalisation, money laundering and female genital mutilation to the appropriate authorities.
Other than as required by law, I will routinely discuss your case with my supervisor (in order to ensure that you get the best service), my supervisor will have access to your details if I am suddenly unavailable (to contact you and offer you ongoing care) and I may talk or write to your GP (but I will not give any personal details beyond what you are working on).
Social Media and Electronic Information Policy
This section outlines the policy of Enso Hypnotherapy with regard to the use of social media and electronic information. If you, as a client, have questions about any aspect please do ask. As the world of technology is constantly changing this document is likely to be updated regularly and the latest version will always be available on my website.
I do not accept friend or contact requests from former or current clients on any social networking site as this can not only compromise your confidentiality (eg if another of my friends saw that you were a friend they may wonder how we know each other) but would also blur the boundary of the therapeutic relationship.
Use of search engines
I do not routinely Google my clients but may very occasionally in a time of crisis. For example, if you had failed to attend a session and I was concerned for your safety I may try to find out about you this way. If I did so, I would tell you about it the next time we met.
Business review sites
You may find my name on business review sites but I have not asked to be on these. Businesses do not get a choice! Clients are free to post whatever they choose and due to confidentiality I cannot comment on anything that is posted. Indeed, anyone (including a competitor) can post anything so it is advisable to be aware that reviews (good or bad) may not be representative of the views of real clients.
It is considered unethical by my professional bodies (the National Society for Hypnosis, Psychotherapy & Mindfulness and the United Kingdom Council for Psychotherapy) to publish testimonials and so you will not find any testimonials coming from me although it is always nice to receive private messages from clients who have completed their therapy.
If you use location-based services on your phone you should be aware that others may surmise that you are a therapy client if you are seen as “checking in” at my address.
It is preferable to use email only for logistical contact (eg to get a reminder of an appointment time) due to the inherent insecurity of email. If you wish to engage in “email therapy” then please use a password protected word document to contain what you wish to say. I can set this up for you if you need it.
As above texting may be used for contact about appointment times. This is preferable to making a phone call as it is easier to respond as I cannot answer the phone if I am with another client. Whether phoning or texting, please only do so between the hours of 8am – 9pm