Privacy Policy for Creative Charlie
Date of Policy: 05/09/2025
1. Introduction
This policy explains how Creative Charlie ("I," "me," or "my") collects, uses, and protects your personal data. I am committed to respecting your privacy and protecting the information you share with me. As a registered member of the BACP, I adhere to the BACP Ethical Framework for the Counselling Professions, which includes principles of confidentiality and data security.
2. Who I Am
I am Charlie Jackson-Allen, trading as Creative Charlie.
For the purpose of the General Data Protection Regulation (GDPR), I am the "data controller" of the personal data I collect from you.
3. The Data I Collect and Why
I collect and process personal data to provide my counselling services effectively and to meet my professional and legal obligations. The types of data I collect include:
- Contact Information: Your name, email address, and phone number. This is so I can contact you to arrange and confirm appointments and communicate any important information.
- Clinical Notes: Brief, anonymised notes on our sessions. These are for my use only to help me remember key details and track our progress. They are stored securely and separately from any identifying information.
- Personal & Sensitive Information: I may collect information about your background, health, and other personal matters during our sessions. This is a normal part of the therapeutic process and is used solely to help me understand your situation and provide effective support.
- GP Details: In certain situations where there is a risk of harm to yourself or others, I may ask for your GP’s contact details so I can contact them in an emergency, as per my professional ethical guidelines. I will always endeavour to discuss this with you first.
- Payment Information: Records of payments for our sessions. I do not store your credit card or bank details directly; all payments are processed securely by my payment provider, Kiku (Sixten Eighty Ltd.).
4. How I Store and Protect Your Data
I take the security of your data very seriously. The information I collect is stored securely in line with GDPR requirements.
- Digital Data: All digital data, including contact information and anonymised clinical notes, is stored on the secure and encrypted Kiku system. The system is password-protected and only accessible to me. Kiku’s own privacy policy provides more detail on how they secure your data (see https://www.wearekiku.com/privacy-notices).
- Hard Copy Data: Any paper notes, if taken, are stored securely in a locked filing cabinet.
- Contact Information: Your name and phone number may be stored on my mobile phone, which is password-protected. I will delete your number once our work is complete.
I will hold your data for a period of up to 7 years after our work together has ended, as required by my professional liability insurance and the BACP. After this period, all your data will be securely and confidentially destroyed.
5. Sharing Your Data
Your personal data will not be shared with anyone outside of Creative Charlie, with the following exceptions:
- Supervision: As part of my BACP membership and ethical practice, I discuss my work with a clinical supervisor. This is to ensure I am providing the best possible service. These discussions are strictly confidential, and I will only ever refer to you by your first name.
- Risk of Harm: If I have a serious concern about your safety or the safety of someone else, I may need to break confidentiality to ensure your and their safety. I will always try to discuss this with you first.
- Legal Requirements: If I am subpoenaed or instructed by a Court of Law to release information, I am legally obligated to do so.
I will never use your information for marketing purposes or sell it to third parties.
6. Your Rights
Under the GDPR, you have the following rights regarding your personal data:
- Right to be informed: You have the right to know how your data is being used. This privacy policy serves that purpose.
- Right of access: You have the right to request a copy of the information I hold about you. This is also known as a Subject Access Request.
- Right to rectification: You have the right to correct any inaccurate information I hold about you.
- Right to erasure: You have the right to ask me to delete your personal data (in certain circumstances). This is also known as "the right to be forgotten."
- Right to restriction of processing: You have the right to limit the way I use your data (in certain circumstances).
- Right to data portability: You have the right to receive your data in a format that can be easily transferred to another service (in certain circumstances).
- Right to object: You have the right to object to me processing your data.
To make a request regarding your data, please contact me directly at charlie@creativecharlie.co.uk. I will respond to your request within one month.
7. Complaints
If you have any concerns about how I handle your data, please contact me first. If you are not satisfied with my response, you have the right to lodge a complaint with the UK's data protection authority, the Information Commissioner's Office (ICO). You can find more information on their website: www.ico.org.uk.
8. Changes to this Policy
I may update this policy from time to time. The latest version will always be available on my website at www.creativecharlie.co.uk.