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Privacy Policy

Working as associate of SafeHaven Trauma Centre 

This applies to Dance Movement Psychotherapy, acupuncture and mindfulness

Whilst working as an associate of SafeHaven Trauma Centre, I adhere to their Privacy Policy – details of which can be found here

It will be clear to you whether or not you are a SafeHaven client i.e. you will have signed a client agreement with SafeHaven Trauma Centre, attend the centre for sessions, and/or receive invoices from SafeHaven if sessions are undertaken remotely.

I am also bound by the professional codes of the Association of Dance Movement Psychotherapy UK and the British Acupuncture Council.

Working in my own practice www.rachelmillsted.com – Acupuncture and Mindfulness

Privacy Policy
I take your privacy seriously and I am fully committed to ensuring that your privacy is protected. This policy provides information on how I use and protect any information that you give me, from when you first make an enquiry, through until after the treatment course is finished or once you have completed a mindfulness course.  

​Third party privacy statement 
​Your information does not get shared with anyone else within my private practice, as I manage my practice myself, and operate my business as an independent ”sole trader”. 

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.
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I never share your information with any third party – unless you have explicitly given me permission to so.

There are 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. This is explained further below.
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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 practitioner.

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. 
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My business is registered with the Information Commissioners Office, the UK authority for upholding data protection, (www.ico.org.uk). I am bound by their policies with regards your privacy, as well as the British Acupuncture Council Code of Conduct.
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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 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. 

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How do I obtain information about you?
I obtain information from:

  • what you have shared 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, by phone and online (via Zoom)
  • your health insurance company or healthcare provider, if relevant, and with your consent 
  • If we agree to work together, we will agree a treatment plan in accordance with the relevant information you have provided about your current situation and your hopes and aims of working together.

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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. 
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My website’s contact form
If you get in touch via my initial contact form, you have the option to decide what information you wish to share with me.
Your information is not stored anywhere on my website – your contact form goes directly through to me via email. 

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Your privacy in our work together 
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Emailing each other 
After we have decided on an initial appointment I will usually send you a confirmation email detailing the venue, fee and other relevant practicalities.
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Online sessions 
Zoom services have updated their privacy measures to ensure they are fully compliant with GDPR regulations 2018. 
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Sessions where we meet in person  
The rooms I use on a weekly basis are dedicated therapy or clinic rooms, either situated within clinics, treatment centres or mixed office spaces.
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Obtaining information from third parties 
If your therapy is being funded via a health insurance company, your insurance company may provide me with information, but this would never be without your prior knowledge and consent, in accordance with your agreed contract with them. Insurance companies typically encrypt or password protect sensitive information that they share. 
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On occasion, with your prior knowledge and consent, I may have reason to ask to obtain information from other healthcare providers involved in your care, for example if you are working with a psychologist, psychiatrist or another therapist. This will only be to ensure I am providing the most appropriate, safe, responsive and effective therapy for your needs.
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If you’re working with another healthcare provider, such as a psychiatrist or psychologist, you or they may wish for me to have information about you, but this is highly unlikely to ever be without your prior knowledge and consent. From 25 May 2018 all organisations and businesses will be required to ensure their privacy policies are fully compliant with GDPR directives. Make sure you know your privacy rights with each party involved in your care.
You have a right to view any information that is shared about you, and a right to have any information rectified that is incorrect. 
I will never knowingly receive information about you that you have not given permission to be shared.
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In rare and exceptional situations a family member, partner or friend may contact me, but that could only happen if you decided to share my details with them. All actions from that point would need to have you at the centre, with your full consent and you guiding appropriate therapeutic decisions at every step of the way.
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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)
  • GP address

If health insurance is funding your sessions I also need your name, DOB, address, plus your membership and authorisation codes to pass security checks with your health insurance company. 

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 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 comprise of: 

  • the emails, reports, forms or letters you have decided to send or ccd 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.

 
Measures I take to store your data securely
These are the measures I take to protect your data before it can be deleted or destroyed:
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Storing paper information securely 
I keep handwritten or printed information about you to an absolute minimum in order to protect your data. 
I do not print or keep duplicate information wherever this can be prevented. For example, if you or your insurance company have sent me digital information via email, I do not then print it. 
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All handwritten or printed information that has any personally identifying information on it about my clients is kept in a securely locked filing cabinet. 
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Keeping electronic information securely stored 
My devices are all password protected, with strong passwords that are all different from each other, and which I change at suitable intervals. 
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I do not share my devices or passwords with anyone else other than the individual who is the executor of my ‘Professional Will’ who has the password for my laptop.  He would only use this in the event of me being unable to work (death, serious illness etc.).  At this point my executor would access my current client list and inform them of the situation.

I do not record Zoom sessions. I ask that you do not record them yourself without my explicit permission. 

If I need to electronically send a report or invoice, I send this separate to your personally identifying information or I password protect the document. 

I do not keep your personal or sensitive information stored on any external hard drive or memory stick. While our work is active, I keep electronic information in the following two places only: 

On my password protected mobile phone

On my password protected laptop


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Who I may need to share your information with

Third parties
There may be occasions when I need to share personal or sensitive information about you with third parties, specifically, your insurance company or other health professionals involved in your care (see below). When I do so, I comply with all aspects of the Data Protection Act 1998 (DPA).
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Your insurance company
If you are claiming the cost of your sessions through your insurance company, your insurance company may request details of your treatment and progress from me in order to authorise further funding for your treatment.  I will share the minimum amount of information necessary with your insurance company.
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Specialist healthcare providers 
If there is a specialist healthcare provider, such as a consultant physician or psychiatrist, NHS mental health service, dietician or nutritionist, psychologist or other therapist involved in your care, and your treatment with them could be negatively impacted if they did not know you were working with me, I consider this very carefully. 
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I will always ask you for your consent before sharing any personal or sensitive information when liaising with other health professionals who may be involved in your care. 
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I will always ask you for your consent before making appropriate referrals to other healthcare providers.
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I will also check with you what information you do and do not wish for me to share. I only share sensitive information that would be of direct importance to your healthcare i.e. directly relevant to you getting the most appropriate treatment for your needs. 
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I would ensure you have a copy of any email or report I send.

General practitioners (your GP)
It is not typically necessary for me to contact a client’s General Practitioner, unless you and I have concerns about the medication or treatment that a general practitioner may be prescribing you, or if your GP is the gateway to enable you to access other healthcare that you need. 
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If I share any information with your GP it will be in written form, in explicit consultation and collaboration with you, with the purpose of you getting better quality health care. I would ensure you have the opportunity to edit before it is sent and that you have a copy of the final draft.
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Legal exceptions to obtaining your consent 
​There are some situations where 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 BACP Standards of Conduct, Performance 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 a sole practitioner like myself. 
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How long do I store your data?
My retention period is seven years after which I will destroy your written case notes and any files I have on the computer.

Your Individual Rights
You have a number of rights when it comes to your personal data. Please do visit  so you can get fully informed about all of your data rights. I have listed three particularly important rights here

Your right of Access 
You have a right to make a written request for the details of personal information that I hold about you.
You can simply email me and I will be happy to share the records that I have for you.
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Your right to rectification
If you believe that any information I am holding on you is incorrect, incomplete or needs updating, please email me with details and I will promptly make the right changes. I will always show you any report or letter I write to a third party before I send it, and invite you to rectify it as you see fit. 
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Your right to portability
Any information that gets generated in our work together, such as reports or letters, you are most welcome to share with other people if that would be helpful to you.  I will do my best to only keep information in a form that is easily portable for your convenience. 
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Your right to lodge a formal complaint 
If you believe that your rights under the GDPR regulation have been infringed, or that the processing of personal data relating to you does not comply with lawful regulation, visit the Information Commissioners Office to find out how such matters can be dealt with on your behalf. Their helpline is 0303 123 1113.