Relational Third is a partnership offering psychotherapy services including assessment, treatment, supervision, consultation and training. We currently operate in the UK and can accept commissions from private individuals, organisations (such as firm of solicitors) and from public bodies (such as a local authority).
In this policy document ‘commissioner’ means someone acting on behalf of an organisation or public body, such as a solicitor or officer of a local authority. ‘Client’ means a person we offer a therapeutic service to, or whose care we are concerned with when, for example, we offer supervision to other professionals. A private individual commissioning a therapy service from relational third is a client rather than a commissioner for the purposes of this policy. In this document ‘you’ refers to private individuals.
We specialise in working in contexts where domestic abuse has occurred. Our aim is to help our clients to be in relationships which are free of violence and coercion. This means that, from time to time, we will need to response to ‘safeguarding’ concerns about a child or adult. This policy should be read on conjunction with our safeguarding policy. A copy of Relational Third’s safeguarding policy is available upon request.
Relational Third takes the security of your data very seriously. All our electronic and online (‘cloud-based’) storage facilities are secure, encrypted and GDPR compliant. Whilst we cannot ensure or guarantee that loss, misuse or alteration of data will not occur, we use our best efforts to prevent this. We will comply with all and any obligations placed on us by the Information Commissioner’s Office, including reporting of data breaches.
What data do we collect?
We do not collect any data about visitors to our website, or use any cookies to track your visit to our website.
When we meet you in person, or speak with you on the telephone, etc., we will collect and process your personal information such as name, email address, postal address, telephone number, gender and date of birth.
If you consent to working with Relational Third, to participate in and assessment or in psychotherapy, we will discuss events in your life history which are relevant to understanding your present circumstances and experiences. If you have consented to an assessment undertaken by Relational Third then we will meet with other family members and/or connected persons. We will collect sensitive personal data, for example, by recording details of your life history. For the purposes of this work, Relational Third is a data controller.
If you are receiving a service from Relational Third that has been commissioned by an organisation or public body, then we will receive information about you from this third party and possibly from other parties. This could be from a local authority, the family courts, etc. You should be told by the commissioner what information is being shared with Relational Third.
Court papers (statements, assessment reports, letters of instruction, etc.)
How will we use your data?
We will use your data to for administration purposes, to set you up as a new client, and to accept payments from you, if that is applicable, and to contact you about your treatment as well as respond to your inquiries.
We will use your data in relation to the professional task you have agreed with Relational Third. This might be to undertake a family court assessment, or to provide you with a psychotherapy or psychoeducation service. We will use your data to aid us in delivering a service to you and in order to be accountable to other parties, where appropriate. For example, if we are meeting you because you have agreed to an assessment as part of family court proceedings, then we are accountable to you and to the family court (the judge).
We will use your data to communicate with you about your assessment or psychotherapy. It is your right to request in what format we contact you, be that by phone, text, in writing or by email. You have the right to withdraw any of these communication methods.
For commissioned services that you have consented to we will use your data communicate with commissioners and other public bodies (for example, by writing a court report).
We will use your data to comply with legal and regulatory obligations, such as reporting a ‘safeguarding’ concern. We do not need your consent or agreement to share information in these circumstances as we are required to do this.
We will use your data to defend or prosecute legal claims. In order to do this we may be required (for example, by a court) to share your data with other parties.
Ways your data will not be used.
We will not use your data for marketing purposes or to make automated decisions (e.g. profiling).
We will not share your data with third parties without your consent or knowledge, except where there are safeguarding concerns, as outlined above.
How will we store your data and for how long?
(1) Clinical notes concerning individuals and families
We will make written notes and create electronic records about our conversations with you.
In making written notes, identifying information will be kept to a minimum. For example, we will not write your full name on notes, using first names or initials instead. We will use Counsel notebooks (perforated pages) and as soon as practicable (for example, at the end of the working day) we will remove notes and store these securely as paper files or as a securely stored and encrypted scanned document. We use a combination of working practices and technology to ensure your information is kept confidential and secure.
Paper filed and encrypted scans will be retained for the minimum amount of time necessary. For example, if we are assessing you as part of family court proceedings we will retain all records until the completion of the proceedings and the instructing solicitor has confirmed that the record is no longer required.
We may be required to share information about you without your consent during the course of our work. For example, we may be obliged in particular circumstances to make a ‘safeguarding’ referral about you or about someone known to you, in order to protect you or someone known to you from immediate or future harm. We will provide you with a copy of our safeguarding policy on request. In these circumstances we may be required to retain data about you. For example, we may be required to retain a record of our concerns and the reasons for making a ‘safeguarding’ referral.
If you request a copy of a clinical record we will redact all third party information. For example, if one member of a couple requested a copy of a record, then all and any information pertaining to the other party would be redacted. In some circumstances we would require the permission of the court to share this kind of data with you.
You can withdraw your consent to work with us at any time. In some circumstances Relational Third may be required to provide a report to the commissioning organisation about our work up to that point and for our opinion as to whether we would recommend that a different service be provided to you. You will have access to any report we write and will have the opportunity to challenge its contents.
If a client requests a copy of a clinical record we will redact all third party information. For example, if one member of a couple requested a copy of a record, then all and any information pertaining to the other party would be redacted. Details of how to make data access requests are set out in this policy document.
(2) Work undertaken on behalf of other organisations
Relational Third works on behalf of other organisations, for example, local authorities, providing services on their behalf. When Relational Third undertakes this work it is a processor of data and not a data controller. This means that the organisation Relational Third works for tells us what data they expect to be processed and is responsible for providing us access to their secure databases where data will be stored. When Relational Third work on behalf of another organisation, will not store any client data electronically on our own systems.
When we work on behalf of other organisations we will always ensure that appropriate agreements are in place to protect your information and keep it safe and secure. This is what the law requires us to do.
During the course of this work we will make written notes. We will use Counsel notebooks (perforated pages) and as soon as practicable notes will be recorded on the databases provided by the data controller. Written notes will then be destroyed, for example, by shredding, as soon as practicably possible after entries have been made on databases. Unless it is necessary to safeguard and protect a person or persons, we will not write client’s full names, dates of birth, or other sensitive personal information in handwritten notes, using first names, initials, unique pin numbers (associated with database files) instead.
Where Relational Third is a data processor and not a data controller, we will forward all access requests to the data control officer within the commissioning organisation and inform you of this person’s details and the date on which we forwarded your request. We will cooperate with the data controller to help them expedite all access requests. We will assist the data controller with their responsibilities
What are your rights?
You have a right of access and may request a copy of any information we hold about you.
You have the right to have any errors of fact contained in this information corrected. We may have been asked to provide a professional opinion about you or someone known to you (a family member, for example). Professional opinions are not facts and you do not have the right to have opinions amended, but we can record that you disagree with a professional opinion.
You have the right to have your personal data erased providing this does not conflict with statutory or contractual obligations Relational Third has entered into.
You have a conditional right to request that Relational Third restrict the processing of your data.
You have the right to object to Relational Third’s processing of your data.
You have a conditional right to ask that we transfer your data to another organisation, or directly to you.
If you wish to access, correct, update or request deletion of your personal information then you should do so in writing (details below). Relational Third will confirm your identity before considering any request. We will respond to any request within 40 days.
What data does our website collect?
Data Protection Officer
If you are not satisfied with how Relational Third has stored or processed your data, or dealt with your complaint, you may wish to report a complaint to the Information Commissioner’s Office.
Further information on how to make a complaint can be found here: https://ico.org.uk/make-a-complaint/