Crossline endeavours to comply with the General Data Protection Regulation (GDPR) of May 2018. This includes your individual rights as a client, (known as the Data Subject for the purposes of this document).
Who We Are and What We Do
Crossline Christian Counselling Service is a professional organisation located in Maidstone in the County of Kent. Crossline has been established since 1991 by Christians who wished to provide a resource to those who were hurting or struggling with life's problems. As such, Crossline is here to serve the people of Kent particularly those living in the local community. Crossline Maidstone is one of several Crossline services across the United Kingdom.
Crossline counsellors are members of either the ACC (Association of Christian Counsellors) or the BACP (British Association of Counsellors & Psychotherapists). Our established counsellors have had appropriate training are qualified and many of them are accredited or working towards their accreditation. Crossline also has a regular intake of Student Placement Counsellors from various colleges in Kent, Surrey and London. The counsellors receive supervision from Supervisors with Post Graduate or MSc qualifications in Clinical Supervision.
Crossline is situated in The Vine Medical Centre on the second Floor
Address: 2nd Floor 13 Tonbridge Road Maidstone Kent ME16 8RL
Tel: 01622 754447
Information We Require From You and Why
If you decide to receive counselling at Crossline you will require an initial assessment with the Senior or Deputy Coordinator. This is to consider whether Crossline will be the most suitable agency to help with your issues, and it also gives you an opportunity to decide whether Crossline is the agency you would like to receive your counselling sessions.
Before your assessment can begin you will be asked to complete a “Record of Personal Information” which includes a consent as to the holding of personal information about you. (GDPR Articles 6.( 1), 7.2, & 9(2) a,d,j). This gives Crossline the right to hold and obtain personal information about you for the purposes of making a decision as to whether Crossline is the most appropriate place to help with your issues, and to choose an appropriate counsellor for you.
On the "Record of Personal Information" you (the client) will firstly be asked to provide general personal information such as Name, Address, Date of Birth, your GP’s name and Surgery address. Secondly, you will be asked to provide more detailed personal information relating to the reason you are requesting counselling. (GDPR Article 15)
This information is necessary for the following reasons:
‘The Record of Personal Information’, also notes that you have the right to access such information that Crossline has about you, rectify such information where it is wrong, and also to erase any information held about you. At your assessment you will be given a copy of this form that also contains this ‘opt out’ clause requesting any information about you to be erased. (GDPR Articles 15, 16 and 17)
After the initial assessment you will be asked to sign a two-way contract with your designated counsellor once therapy commences.
Unless you make a request for your information to be erased Crossline and your counsellor will store your data for 5 years from the date you end your counselling contract. The retention period is calculated in relation to client information that might be needed by a court of law.
Please note that by not providing the required information counselling will not take place.
Who Will See Your Personal Information?
Record of Personal Information
Before your assessment can begin you will be asked to sign a ‘Record of Personal Information’ (GDPR Article 6 (1) a 7 (2) & 9 a,d,j) giving Crossline the right to obtain your personal information by the Senior/Deputy Coordinator and only they are allowed to see these details
The Assessment Form:
‘The Assessment Form’ is compiled from the information provided by you and any other information obtained about you by the Senior/Deputy Coordinator and only they and your designated counsellor are allowed to see these details.
Crossline holds information about you on the Assessment Form which is initially typed out on the computer. Crossline retains three copies:
Once the assessment forms are printed out all the information is then deleted from the computer.
The Case Notes:
‘Case notes’ are written by your counsellor these will also be coded to protect your identity. This will be a separate code from the one Crossline holds. Unless for any reason these case notes are subpoenaed (ordered) by law only the counsellor has access to your notes.
You will be asked to sign a ‘Discharge Form’ acknowledging your counselling contract has ended with your counsellor. You will keep the original copy indicating your decision to either retain or erase your personal information. Crossline will retain two of these copies which will be kept for 5 years from the date you sign the form, and only the Senior/deputy Coordinators and your counsellor are allowed to see these details.
How Will We Use This information About You?
For the purposes of:
Purpose and Legal Basis for Processing Your Information
Under no circumstances will Crossline be involved with marketing your personal information
Necessity to Perform a Task in the Public Interest or Exercising an Official Duty
Crossline adheres to a strict code of confidentiality, however, confidentiality has its limitations and there may be certain circumstances such as harm to self or others which will compromise this principle. Clause 7 ‘Crossline Conditions of Counselling’ ‘Therefore no contact will be made with your church, doctor or other professional agencies without your express permission unless on rare occasions Crossline feel it necessary to contact the appropriate people relating to either the safety of yourself or others.’
In such circumstances Crossline or your counsellor may have to contact designated outside agencies such as The Police, Social Services or GP because the issue is in direct conflict with our legal or ethical obligations as a counselling agency. This would include situations such as,
ongoing sexual abuse involving a minor, (a child under the age of 18), selling illegal substances, any intention to commit any act of terrorism. These examples are not exhaustive.
Data Controllers and Processors
The Trustees hold overall responsibility for the charity. However, for the purposes of obtaining, filing, processing and keeping your personal information confidential the Senior Coordinator, Caroline Mennie, and the Deputy Coordinator, Elaine Day are the Data Controllers, and Data Processors. Once you are allocated a designated counsellor then this counsellor will also become a Data Controller and Data Processor. (GDPR. Article 13 (1)a.c (2)Article 24 (1) (2))
Your Rights as a Data Subject
You are the Data Subject and you have the right to obtain your personal information from Crossline and your Counsellor (GDPR. Recital 63) However, in certain circumstances it might not be in your best interests to have full access to all your information related to your counselling sessions. For example, in a domestic violence situation. Therefore, you will only be given aspects of your personal information to ensure best practice, your safety and your well-being. (Data Protection (Subject Access Modification) (Health) Order 2000 No 413)
At the time of writing Feb 2018, the GDPR (General Data Protection Regulation) hasn’t written a specific policy regarding the above policy. Crossline abides by BACP and ACC ethical framework which is always concerned with putting client safety first. BACP: 9. (2106) states, ‘We will give careful consideration to how we manage situations when protecting clients or others from serious harm or when compliance with the law may require overriding a client’s explicit wishes or breaching their confidentiality’ ACC: 7.1. (2004) to take responsibility for ethical judgements and base their ethical judgements on the principles within it. 184.108.40.206 (2004) the overriding objective must be to protect all concerned from harm.
The right of rectification: You are also entitled to view your information to check the information is accurate. (GDPR. Article 16,17,18,19)
Crossline has a document called the ‘Conditions of Counselling’ If counselling is to take place you and your counsellor are required to sign two of these documents. One is for you to keep for your records and the other one is for your counsellor to keep for their records. This document forms the contract between you and your counsellor informing both of you of your contractual responsibilities and obligations whilst you are receiving counselling at Crossline. (GDPR. Article.7.2, & Article.9) This document also includes a clause stating, ‘Either party can suggest that the contract is ended at anytime and an ending will be arranged.’ (GDPR. Article.7.3, & 17) Withdrawing consent gives you the right to have your personal data erased.
The right to erasure: You might decide not to go ahead and commence counselling at Crossline and decide to withdraw your consent to information being held by us in which case Crossline will erase your data, or you might decide to receive counselling and request your data be erased once the counselling contract has ended. Again if you agree to counselling you will be asked to sign the ‘Conditions of Counselling’ which includes a clause stating, ‘Either party can suggest that the contract is ended at anytime and an ending will be arranged.’ (GDPR. Article.7.3, & 17) Withdrawing consent in this manner also gives you the right to have your personal data erased. If you request that you wish your information to be erased you must sign the ‘opt out’ clause on the ‘Record of Personal Information’ or the ‘Discharge Form' and either hand it to the Senior or Deputy Coordinator or your Counsellor who will give you a photocopy of this document for your records. Crossline will destroy ‘The Record of Personal Information’ and/or the ‘Discharge Form’ five years from the date it was signed.
The right to restrict processing: the Data Subject has the right to obtain from the data Controller restrictions of processing where the following applies, the accuracy of the data is contested by the data Subject, the processing is unlawful, the Data Controller no longer needs the information, but they are required by the Data Subject for the establishment, exercise or defence of legal claims, the data Subject has objected to processing (GDPR Article 18 Article 21 (1)
The right to data portability: this right allows the Data Subject to obtain and reuse their data for their own purposes across different services. It allows the Data Subject to move, copy or transfer their personal data easily from one IT environment to another in a safe and secure way without hindrance to usability. (GDPR Article 20 Recital 68
The right to object: the data subject has three rights to object to processing. The only absolute objection is to direct marketing. The other two rights relate to scientific/historical/research/statistical purposes/ or it’s necessary for the public interest/official authority. There must be adequate grounds for the data subject to make an objection. (GDPR Article 21)
Rights of automated decision making and profiling: Automated decision making is a decision made solely by an automated process with no human involvement in the decision process. Some of these decisions could have a legal effect for example a contract which could impact on the Data Subjects individual legal rights.
Profiling is obtaining personal data via an automated process i.e. a computer with the aim of evaluating personal aspects of the person or groups of people for example age, gender, which might include analysis or prediction. An example of profiling includes analysing an individual’s credit score. Apart from CORE34 for statistical purposes Crossline never uses automated decision making.
The right to complain: You have the right to make a complaint to a supervisory authority if you believe the service you are receiving is inadequate (GDPR. Article 15 (1) f). Senior or Deputy You can make a complaint in two ways:
Data Breach: In the unlikely event your personal information is breached in anyway the Data Controller will inform the supervisory authority within 72 hours after having become aware of the breach, unless the Data Controller is able to demonstrate, in accordance with the accountability principle, that the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. (GDPR. Article. 33)
Frameworks for Work Undertaken by Crossline
Crossline is also obliged to comply and work within the framework of the Crossline Policy Document as well as the following organisations:
BACP (British Association of Counsellors and Psychotherapists) www.bacp.co.uk Ethics and Standards Ethical framework for the Counselling Professions July 2016
ACC (Association of Christian Counsellors) www.acc-uk.org Ethics and Practice 2004
CCPAS (Churches Child Protection Advisory Service) www.ccpas.co.uk Model Safeguarding Policy 2013
Contact Crossline directly: Crossline Policy Document. This can be obtained at Crossline by asking one of the Coordinators.
Working with Young People their Parents/Carers
Young people must be 15 years or over. In exceptional circumstances children from the age of 13 years may commence counselling prior to their 15th birthday. When Crossline is trying to decide whether a child is mature enough to make decisions relating to their suitability to access counselling ‘Gillick Competency’ is applied.
Currently written consent must be obtained from either the parent or carer, and the young person before counselling commences. (GDPR Article 8 (1) However, Recital 38 includes the following sentence, ‘The consent of the holder of parental responsibility should not be necessary in the context of preventive or counselling services offered directly to a child.’
Confidentiality is a complex issue and will have its limitations. Young people will not be offered levels of confidentiality that could prove impossible to keep, however, every effort will be made to respect, maintain, and protect the confidential nature of the counselling relationship with the young person in order to balance the young person’s rights with Crossline’s responsibility to keep the young person safe from harm.
Gilmore, S. and Herring, J. (2011) “NO” is the hardest word: consent and children’s autonomy. Child and family Law Quarterly, 23(1): 3-25
The statutory duty regarding the protection of children and vulnerable adults takes priority over client confidentiality. When a child or vulnerable adult is at risk the Children and Vulnerable Adult Policy will be implemented. Therapy for children following sexual abuse is often carried out by organisations such as the NSPCC or an appropriately qualified Social Worker. As this is a very specialized area it is agreed that Crossline counsellors will not commence counselling with a young person who is known to have been sexually abused unless this has occurred several years previously and any court cases finalized.
Protection of Children and Vulnerable Adults
This policy relates to any counsellor who is part of the Crossline team and is counselling young people and vulnerable adults. Each counsellor has the direct responsibility to keep young people and vulnerable adults with whom they have contact safe. A copy of the full Child and Vulnerable Adults Protection policy is available at Crossline.
All counsellors are subjected to Disclosure and Barring Service (DBS) checks.
Crossline abides by the ACC Code of Ethics and Practice, is a member of The Churches’ Child Protection Advisory Service and is registered under the Data Protection Act (DPA).
Crossline is committed to listen to, relate effectively and value children, young people and vulnerable adults ensuring their protection within Crossline.
The Children’s Act 1989 makes it clear that the term ‘child’ used in the Act refers to any young person under the age of 18 years old. This document should be read in conjunction with Crossline’s Manual and Policies.
The person in Crossline who has overall responsibility for child protection is the Senior Co-ordinator, Caroline Mennie Senior Child Protection Officer, and if she is unavailable her deputy Elaine Day, Deputy Child Protection Coordinator.
Other Resources and Information
Kidscape: books, resources and training in the area of child self-protection, bullying and keeping children safe. www.kidscape.org.uk
Crossline is a member of The Churches’ Child Protection Advisory Service (CCPAS). They can be contacted for advice at
CCPAS, PO Box 133, Swanley, Kent, BR8 7UQ.
Tel: Lo-call 0845 120 45 50 or STD 01322 517817 Email: email@example.com
Office opening hours - 9am to 5pm Mon-Fri with an out of hours emergency helpline.
In order to safeguard those in our organisation we adhere to the UN Convention on the Rights of the Child and have as our starting point as a definition of abuse, Article 19 which states:
Also for adults the UN Universal Declaration of Human Rights with particular reference to Article 5 which states:
Detailed definitions, and signs and symptoms of abuse, as well as how to respond to a disclosure of abuse, are included in the Crossline Policy which can be obtained at Crossline Christian Counselling Service.
Social Media Policy
This document outlines Crossline policies relating to use of Social Media. Crossline does not hold any professional Social Media accounts for use as an online forum to promote our organisation. As new technology develops and the internet changes, there may be times when we need to update this policy. If we do so we will notify you in writing of any policy changes and make sure you have a copy of the updated policy.
Crossline counsellors will not accept friend requests from current or former clients on any social networking site. We believe that adding clients as friends on these sites can compromise your confidentiality and our respective privacy. It may also blur the boundaries of the therapeutic relationship. If you have questions about this please raise them in session with your counsellor or contact the Senior Coordinator ‘Caroline Mennie’.
Crossline counsellors may hold a personal Facebook page but will not accept friend requests from past or present clients of Crossline. Crossline and its counsellors believes that having clients as Facebook friends creates a greater likelihood of compromised client confidentiality, and feel it is best to be explicit to all who may view their list of followers to know that they will not find client names on that list.
Crossline counsellors may also hold other personal Social Media accounts also such as blogs, Twitter, Linkedln, as may you our client. We have no expectation that clients will want to follow these media streams. However, if it is picked up that you have followed on these forums, we may briefly discuss it and its potential impact on the therapeutic relationship. Crosslines’ primary concern is your privacy. Crossline and its counsellors will not search Facebook or follow current or former clients on blogs or Twitter. Our reasoning is that we believe casual viewing of client’s online content outside of the therapy hour can create confusion in regard to whether it’s being done as part of your treatment or to satisfy our personal curiosity. In addition, viewing your online activities without your consent and without explicit arrangement towards a specific purpose could potentially have a negative influence on the therapeutic relationship.
Please do not attempt to use messaging or social Networking Sites such as Twitter, Facebook, or Linkedln to make contact with your counsellor. These sites are not secure, and the counsellor may not read your messages in a timely fashion.
Please do not use these and other forums to engage with Crossline or your counsellor in public online if there is an established therapeutic relationship. Engaging in this way could compromise your confidentiality. For legal purpose it may also create the potential for the need for this information to be documented and archived in your notes. If you need to contact Crossline/your counsellor between sessions please do so by phone (following the instructions on answer machine if not answered).
Direct email at firstname.lastname@example.org is second best for quick, administrative issues such as changing appointment times. See the email section below for more information regarding email interaction.
USE OF SEARCH ENGINES
It is NOT a regular part of Crossline or its counsellors’ practice to search for clients on Google, Facebook or other search engines. Extremely rare exceptions may be made during times of crisis. If we have a reason to suspect you are in danger, and you have not been in touch with us via our usual means (coming to appointments, phone, or email) there might be an instance in which using a search engine (to find you, find someone close to you, or to check on your recent status updates) becomes necessary as part of ensuring your welfare. These are unusual situations, and if we ever resort to such means, we will fully document it and discuss it with you.
We do not follow former or current clients on Google reader and Crossline and its counsellors do not use it to share articles. If there are things you wish to share with us that you feel are relevant to your treatment we encourage you to bring it to your next session with your counsellor.
BUSINESS REVIEW SITES
Crossline can be located directly via: www.crosslinecounselling-maidstone.org it can also be located on sites such as Google Local, Bing, or other places which hold listings. Some of these sites include forums in which users rate their providers and add reviews. Many of these sites comb search engines for business and automatically add listings. If you should find us listed on any of these sites, please know that our listing is NOT a request for a testimonial, rating, or endorsement from you as our client.
Of course you have a right to express yourself on any site you wish. But due to confidentiality, we cannot and would not respond to any review whether negative or positive. We urge you to take your own privacy as seriously as we take our commitment of confidentiality to you. You should also be aware that there is a good possibility when using these sites to contact us indirectly we may never see it. You are more than welcome to tell anyone you wish that you attend Crossline or how you feel about the therapy we have provided you, in any forum of your choosing. If you do choose to share on a business review site, we hope you will keep in mind that you may be sharing personally revealing information in a public forum. Crossline would urge you to create a pseudonym that is not linked to your regular email address or friend networks for your own privacy and protection.
Crossline seeks to provide the best possible service to you. If you have a complaint to make you can contact the Senior Coordinator (Mrs Caroline Mennie) in writing who will attempt to solve your issue or if required she will discuss the issue with the Trustees. Crossline is affiliated with the ACC (Association of Christian Counsellors). Details of their complaints procedure can be found on their website www.acc-uk.org and found in their Code of Ethics and Practice. Crossline's aim is to work in accordance with their guidelines.
Crossline prefer email is only used to arrange or modify appointments. Please do not email content of your therapy sessions, as email is not completely secure or confidential. If you choose to communicate with us by email, be aware that all emails are retained in the logs of your and our internet service providers. While it is unlikely that someone will be looking at these logs, they are, in theory, available to be read by the system administrator(s) of the internet service provider. You should also know that any email we receive from you and any responses that we send you will be stored and kept by your counsellor along with their notes
If you have any questions or concerns about any of these policies and procedures or regarding potential interactions please contact the Senior Coordinator Caroline Mennie.