Covid-19 Face-to-Face Counselling Policy
1. Managing Risk
2. Suitability for Face-to-Face
3. The Journey - Coming to and Leaving the Session
4. Entering and Leaving the Building
5. Hygiene – Handwashing, Sanitation and Toilet Facilities
6. Within the Counselling Suite
7. Session Times
8. Test and Trace
A risk assessment has been carried out by me and in accordance with the Health and Safety Executive and Government guidelines as of 15th June 2020, which must be followed in conjunction with this Policy. It is important that all actions within it are followed by both me and clients for our safety and continuity of counselling. The risk assessment will be reviewed monthly and I will amend/update this Policy should there be a second peak or Government guidelines are amended/updated.
1. Managing Risk
The counselling suite is 18.76 square metres in size, and the sofas are opposite each other and approximately 3 metres apart allowing for social distancing without interruption to the therapeutic experience.
Even with social distancing there is risk of airborne transmission in an enclosed area, so I have installed a Dyson Hot+Cool Air Purifier. It has HEPA glass filters that can capture microscopic particles up to 2.5 microns in size. Asymptomatic Covid-19 particles start at 0.5 microns, and increase up to 3 microns in size when symptoms are present through coughing and sneezing.
It cannot be guaranteed that the HEPA filter will capture all Covid-19 microns at their smallest size, but it is believed that the concentration of the virus is so low at this stage that you would need to be inhaling them for approximately 90 minutes to have ingested enough to contract the virus. The 0.5 sized microns also have a short survival timespan.
Some of the microns (droplets) will fall onto surfaces before they can be circulated by the Dyson and so specific measures have been put in place to carry out intensive cleaning daily for hard surfaces, and weekly for soft furnishings.
2. Suitability for Face-to-Face Counselling
It is unsafe for you to have face-to-face counselling if you are considered clinically vulnerable or extremely clinically vulnerable. You can click on each of the links for a list of conditions that apply to these two groups. Please also consider whether anyone you will come into close contact with is in either of these groups.
Please also consider how you feel about face-to-face counselling and whether it is likely to add to your anxiety afterwards with concerns that you may have contracted the virus.
3. The Journey - Coming to and Leaving the Session
It is important that you consider how you will get to the session. If you need to access public transport it is a requirement that you wear a face mask and gloves.
If you are driving you may need fuel? Please use gloves as there is a high risk of transmitting and contracting the virus via the handle of the petrol pump. Also use garages where there is a facility to pay at the pump wherever possible.
Will you need a lift from someone outside of your household? If so, then it is not appropriate for you to attend face-to-face sessions as this would conflict with the current Government guidelines.
4. Entering and Leaving the Building
Please wait in the car park for me and I will greet you a few minutes before the session is due to start. I will hold the main door open from the outside so you can enter at a safe distance. The stairs are directly to the left of the entrance and the handwashing facilities are at the top of the stairs. All internal doors will be pinned open except for the toilet door. I will follow behind you at a safe distance.
There is a Covid-19 station with hand gel available in reception when you enter the building which you can use, or you can use the aforementioned hand washing facilities.
Please limit the number of personal belongings you bring into the building, but if this is not possible, I have a coat stand that you can hang bags on within the counselling suite.
At the end of the session I will lead as we exit the building, so you do not have to touch any door handles. I will also open the main entrance door and step outside allowing you to leave at a safe distance.
5. Handwashing, Sanitation and Toilet Facilities
There are male and female toilets which both have warm water, soap, and paper towels. Hand washing is requested prior to the start of the session. It is also advisable to wash your hands after the session on the way out.
Toilets are a significant place of contamination so if you can, please use your own toilet before you leave for the session to reduce the possibility of transmission and contraction. The toilets are cleaned regularly and only a couple of offices are occupied on the first floor, but I would still recommend avoiding using them if possible.
6. Within the Counselling Suite
Please use the sofa to the left of the room as you walk in. There is hand sanitizer on the table which I will ask you to use if we work with any of the arts and crafts, stones/crystals, Russian dolls or sand. I also have hand wipes available.
I have disposable plastic cups which I will let you select, and I will pour the water from a large refrigerated glass bottle. Please let me know in advance of our session if you require water at room temperature.
There are tissues on the small table to the right of the sofa which can easily be removed without making contact with the main box.
7. Session Times
Please allow a few minutes prior to and after the session for us to get settled and then prepare to leave.
I have ensured that there is adequate time in between sessions for the room to be cleared and ventilated. I will do my best to ensure we do not meet anyone else when entering and leaving the building, but if this does happen, please be mindful of the 2-metre distancing guidance. This is a relatively small office building with few occupants so this should not be a common occurrence.
8. Track and Trace
Shieling House and my counselling suite are Covid-Secure in line with Government guidelines as of 15th June 2020. As such you do not need to give my name, nor I yours, to the NHS 'test and trace' teams should either of us contract Coronavirus.
It is important that you still notify me if you become unwell as you will be unable to attend your session.
Data Retention and Privacy Statement
Data Retention, Privacy and Security Statement
1. Your Rights under the General Data Protection Regulations (GDPR)
2. Privacy Statement
3. Security Statement
- a. My Responsibility to You
b. Your Responsibility to You
4. Information Commissioner’s Office
1. Your Rights Under the General Data Protection Regulations (GDPR)
You have the right to be informed about my use of your personal data.
You have the right to be informed about my storage of your personal data.
You have the right to be notified if I lose your data or suffer a breach/cyber-attack and your data is compromised.
You have the right to access your personal data or rectify it if it is incorrect.
You have the right to be forgotten by requesting I destroy or delete your data.
2. Privacy Statement
Data Retained
For me to meet my professional obligations to you, it is necessary for me to obtain and retain some identifying information. This is recorded in an Initial Contact Form and consists of your full name, address, telephone number, email address, and the name and number of an emergency contact.
At the end of our contract I complete a File Closing Sheet which contains the duration of our contract, number of sessions, reason for ending and the date the paperwork can be destroyed.
Any personal information will not be shared with anyone; will only be used as permitted by Law; and will be destroyed after seven years from termination of our contract.
Place of Retention
My practice is run from a large open plan office and counselling suite at Shieling House, 30 Invincible Road, Farnborough, Hants, GU14 7QU. All data and equipment are secured at this office which is only accessed by myself and is locked in my absence.
All sensitive information is stored securely in a locked filing cabinet in my office, which is within a private office building with a secure alarm system and external CCTV recording.
Telephone Correspondence
Your telephone number will be stored securely onto my work Apple smartphone which has facial recognition and passcode protection. Your details will be deleted from my smartphone at the end of our contract. I will delete text messages once I have read them unless we agree otherwise. I would recommend you also do this.
I prefer to use WhatsApp to text which has end to end encryption, which means it is still protected whilst in transit from my device to yours.
Email Correspondence
My email provider is ProtonMail with an upgraded service which encrypts emails in transit, sent and received by me. I will be notified in the unlikely event of a breach of ProtonMail’s systems. Although it is not necessary for you to use ProtonMail to communicate with me, I would recommend you use a secure email provider such as ProtonMail or Hushmail for all sensitive emails such as ours, GPs, banks etc; which is free for personal use.
Please be aware that the subject line of an email is never encrypted, even if the main body of the email is.
Questionnaires and Session Notes
The software I use for these is Pragmatic Tracker which is endorsed by the British Association of Counselling and Psychotherapy and is fully encrypted. I have attached a document with more detailed information for your convenience. In addition, no identifying information is contained within the notes in the unlikely event of anyone gaining access to my login details.
I take brief notes after our sessions using this software. There are various assessment, progress and feedback questionnaires that I use during the course of our work together which are also managed using Pragmatic Tracker. Any additional paperwork is anonymised using a client coding system and retained in the locked filing cabinet in my office.
Supervision
I am required professionally and ethically to access supervision to discuss my caseload and therapeutic work. My supervisor will not have access to any of your personal information or contact details and I will only refer to you by your first name. My supervisor is BACP accredited, adheres to their ethical framework and is also bound by confidentiality.
In Case of an Emergency
In the event of my death or an emergency rendering me unable to contact you myself, my supervisor Suzie Shepperson will have access to my Clinical Will and will notify you. My Clinical Will is password protected and secured by my personal next of kin which may result in a short delay in notifying you.
3. Security Statement
3.a My Responsibility to You
Hardware
I use a HP desktop with McAfee LiveSafe Malware and Firewall protection, password protection, and the screen locks after five minutes of inactivity. The screen is positioned in such a way that prevents anyone in any part of the room from seeing any content.
The Wi-Fi is password protected.
I use a HP printer which is connected to my desktop using a USB cable.
I use an iPhone X with face recognition and passcode. The only software I access is listed below and none of the hardware is synchronised. I do not use the iPhone for video conference counselling.
Software
ProtonMail, Doxy.Me, Pragmatic Tracker, Microsoft Office, iMessage and WhatsApp. All are encrypted within themselves and accessed on my desktop or iPhone which are both password protected.
Cyber Safety
I am a member of www.privacy4.org and have been externally assessed and validated by the Privacy4 Council. I conduct weekly checks on software to assess for vulnerabilities and use a separate portable back-up device which is updated weekly and secured within the locked filing cabinet in my office.
Social Media
I have business pages on various social media platforms, but these are not confidential so please do not use them to communicate with me.
3.b Your Responsibility to You
Please do not communicate via email or text regarding anything other than administrative matters unless you are sure your devices are secure and cannot be accessed by other parties – including partners.
Please do not ask anyone else to contact me or communicate with me on your behalf without discussing it with me first.
Please be mindful that if you communicate with me via work devices, they may be tracked by your employers as their lawful owners. As such, the content on them (calls, emails, text messages, video conferences) is the possession of your employer, not you.
4. Information Commissioner’s Office (ICO)
I am registered with the Information Commissioner’s Office, registration number ZA547265.
If you wish to complain about my use of your personal data, please bring this to my attention in the first instance, Lisa J. Stalley, Data Controller and Processor.
If you are still dissatisfied, please contact the Information Commissioner’s Office by clicking on this link.
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