Privacy Policy
As you may be aware, Guernsey has introduced legislation replicating many of the provisions of the European Union General Data Protection Regulations. This legislation came into effect from 25 May 2018 and applies to certain data collected and held by Karen Le Marchant, Counsellor (“KLEM”) during the course of my relationship with you. You have the opportunity to opt out of receiving communications from KLEM or the processing of your data by KLEM at any point during our relationship.
What information and data I collect and store:

•  Contact details as provided by you when you engaged my services and as updated from time to time. This includes, but is not limited to, title, name, phone, email and postal address.

•  Your birth-date if you provided it.

•  Email communications between yourself and KLEM, none of which are held for longer than six months.

•  Brief notes on our sessions, not identifying you by name.
How I use your information and data:
•  For the provision of services to you, including the organisation of appointments and communication of updates and relevant information.

•  To contact relevant health professionals where necessary and in the circumstances agreed with you in the medical consent you have provided.

•  For supervision, as required by the National Counselling Society as described in our contract.

•  A professional colleague has access to your name and contact details whilst you are my client in case of my sudden death or incapacitation.
Please note that, other than described above, or as otherwise agreed in your contract with KLEM, I will not pass your information or data to any third party without your explicit agreement.
Your data, as described above, is held on electronic devices owned by KLEM and is not held on any server or online data hosting service other than email records. If you give your permission for your data to be handed to a third party, I will rely on them being compliant with the relevant GPDR-equivalent
legislation applicable in their jurisdiction.
You can amend, or request the permanent deletion of, your details at any point by sending a request to karenlemarchant@gmail.com 
Change of purpose

I will only use your personal data for the purposes for which I collected it.
Sources of personal data
I collect personal data via the completion of contracts and agreements provided to you and completed by you, from correspondence including email, from our sessions together.  
Data Security

I have put in place appropriate security measure to prevent your personal data from being accidentally lost, altered, disclosed, used or accessed without authorisation. I have in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator or a suspected breach where I am legally obliged to do so.
Data Retention

KLEM only keeps data for as long as is necessary to fulfil the purposes (as set out above) for which I collected it. Details of retention periods for different aspects of your personal data is available from me.  
Once our business relationship ends, I will retain and securely destroy your personal data in accordance with my record retention and destruction policy, applicable legislation and/or regulatory requirements.
Data subject's rights

As a data subject you have certain rights in respect of your personal data. You have the following rights:

•  Right of access - you have the right to request a copy of the personal data that I hold about you and to check that I am lawfully processing that data. You will not have to pay a fee to access your personal data (or exercise any of the other rights).

•  Right of rectification - you have the right to correct data that I hold about you which is inaccurate or incomplete.

•  Right of erasure - of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me to continue to process it. 

•  Right to restrict processing - this enables you to ask me to suspend the processing of your personal data for example: if you want me to establish its accuracy or the reasons for processing it.

•  Right of portability - you have the right to have the data I hold about you transferred to another organisation.

•  Right to object - you have the right to object to certain types of data processing. You also have the right to ask me to delete or remove personal data where you have exercised your right to object.

•  Right to object to automated processing including profiling – I will not undertake any automated processing or profiling.
If you wish to exercise these rights you should send the request in the first instance to karenlemarchant@gmail.com

Status

This Privacy Notice sets out my current policy as regards the maintenance and processing of personal data.  It does not form, and should in no way be construed as, a contract and no contractual rights or causes of action shall arise in relation to or consequence of the content of this Notice.
Changes to this Privacy Notice

I keep this Privacy Notice under review and any updates will appear on my website at www.karenlemarchant.com 
I last updated this Privacy Notice on 30 September 2018.
Contact details

All enquiries in respect of this Privacy Notices, any complaints about the way in which your personal data is being processed, or any request to exercise any of the rights set out above should be directed me via email at karenlemarchant@gmail.com , telephone 07781 192832
Complaints

In the event you wish to make a complaint about how your personal data is being processed or how your complaint has been handled you have the right to lodge a complaint directly with the Guernsey Data Protection Commissioner either via email enquiries@dataci.org or by post at:
The Office of the Data Protection Commissioner, Guernsey Information Centre, North Esplanade, St Peter Port, Guernsey GY1 2LQ.
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