Your privacy is very important to me, and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to me. I adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

This privacy notice tells you what I will do with your personal information from initial point of contact through to after your therapy has ended, including:

• Why I am able to process your information and what purpose I am processing it
• Whether you have to provide it to me
• How long I store it for
• Whether there are other recipients of your personal information
• Whether I intend to transfer it to another country
• Whether I do automated decision-making or profiling
• Your data protection rights

I am happy to chat through any questions you might have about my data protection policy, and you can contact me via email.

‘Data controller’ is the term used to describe the person/ organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is me.

I am registered with the Information Commissioner’s Office.

My email address is: sfoxcounselling@gmail.com.

My lawful basis for holding and using your personal information

The GDPR states that I must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which I am processing your data. I have explained these below:

If you have had therapy with me and it has now ended, I will use legitimate interest as my lawful basis for holding and using your personal information.

If you are currently having therapy or if you are in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of our contract.

The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for me processing any special categories of personal information is consent initially. I will then retain any counselling records in case of the need to reference them in the future. This period ensures compliance with potential legal claims, professional accountability, and continuity of care. By processing this data, it provides consent that you have contacted me and agree to receive communications from myself.

Initial Contact

When you contact me with an enquiry about my counselling services, I will collect information to help me satisfy your enquiry:

• Name: Collected when you submit an enquiry form
• Email address: Used to respond to your enquiry and communicate about counselling services

Alternatively, another health professional may send me your details when making a referral or a parent or trusted individual may give me your details when making an enquiry on your behalf.

If you decide not to proceed, I will ensure all your personal data is deleted within 6 months. If you would like me to delete this information sooner, just let me know.

While you are accessing counselling

Rest assured that everything you discuss with me is confidential. That confidentiality will only be broken if:

• There is a serious risk of harm to you or to others.
• Matters relating to a disclosure to the Terrorism Act (2000), the Drug Trafficking Offences Act (1993), and the Money Laundering Regulation (2017).
• A court order from a judge.

I will always try to speak to you about this first, unless there are safeguarding issues that prevent this.

I will keep a record of your personal details to help the counselling services run smoothly. This will initially include your name, address, phone number, emergency contact, GP details, and general history. I keep brief notes on our sessions to ensure continuity of care and for reflective practice while therapy continues. These details are kept securely on a password protected laptop, with further password protected software and written notes of sessions are kept on an encrypted cloud storage platform. These details are not shared with any third party.

After counselling has ended

Once counselling has ended your records will be kept for 5 years from the end of our contact with each other and are then securely destroyed. If you want me to delete your information sooner than this, please let me know.

Sharing your information

I will not share your personal information unless there is a clear reason to do so. Depending on the circumstances, I may share limited information with the following people or organisations where this is necessary, proportionate and lawful:

• my clinical supervisor/consultant
• my professional body (BACP), if required in relation to a complaint or ethical matter
• safeguarding services, emergency services or your GP, where there is serious risk or safeguarding concern
• a court or legal authority, if required by law
• an appointed clinical executor if I die or become unable to contact clients and supervisees myself

Where I share information, I aim to share only what is relevant and necessary for that purpose. If I or one of my providers transfers personal information outside the UK to a separate organisation, I will only do so where the law allows it, and an appropriate transfer mechanism or other safeguard is in place where required.

Like other ethical therapists and supervisors, I use clinical supervision to support safe and effective practice. In supervision, I may discuss aspects of client work to support safe and effective practice. I aim to minimise identifying detail where possible and appropriate, and my supervisor is also bound by confidentiality and professional standards.

Clinical Will

I have a professional clinical executor for my Professional Therapeutic Will. In the unfortunate event I am unable to contact you myself, they will have access to the minimum information needed to contact current clients/supervisees and manage records appropriately. That person would be bound by confidentiality, would only access information if necessary, and would not take on an ongoing therapeutic or supervisory role.

Third party recipients of personal data

I sometimes share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks. In such cases I have carefully selected which partners I work with. I take great care to ensure that I have a contract with the third party that states what they are allowed to do with the data I share with them. I ensure that they do not use your information in any way other than the task for which they have been contracted.

The third parties I have identified as processing personal data on my behalf include:

• Lloyds: Bank (payments & online transactions)
• FreeAgent: Accounting software (bookkeeping)
• HMRC: Government department (tax administration)
• Microsoft Teams: Communications technology company (online meeting software)
• YouFibre: Telecommunications company (internet provider)
• WordPress: Website host (cookies)
• Google: Tech company (email)
• Lenovo: Tech company (hardware)

If/when I share any personal data with any of the above processors, I confirm that I have a fully compliant contract with them.

Your rights

I try to be as open as I can be in terms of giving people access to their personal information. You have a right to ask me to delete your personal information, to limit how I use your personal information, or to stop processing your personal information. You also have a right to ask for a copy of any information that I hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at ico.org.uk/your-data-matters.

If I do hold information about you I will:

• give you a description of it and where it came from;
• tell you why I am holding it, tell you how long I will store your data and how I made this decision;
• tell you who it could be disclosed to;
• let you have a copy of the information in an intelligible form.

You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you.

To make a request for any personal information I may hold about you, please put the request in writing addressing it to sfoxcounselling@gmail.com.

Data Protection Concerns & Complaints

If you have any complaint about how I handle your personal data, please do not hesitate to get in touch with me by emailing the contact details given above. I would welcome any suggestions for improving my data protection procedures. I will acknowledge any complaint within 30 days, keep you informed of progress, and explain the outcome. If I am uncertain of the identity of the person making the complaint, I may request additional identification information (such as phoning you on the number I have on file or checking with you your date of birth). If you are complaining on behalf of someone else, I will be obliged to check you have the authority to act on their behalf (either confirmation of power of attorney or a signed letter of authority from the person you are writing on behalf of).

In any complaint please include:

• your name
• what your concern is about
• what you would like me to look into
• how you would prefer me to respond

GDPR regulations require individuals to complain directly to the organisation that processes their personal data before escalating to the Information Commission’s Office (ICO). However, if you have done so and are not satisfied with the outcome and want to make a formal complaint about the way I have processed your personal information you can contact the ICO which is the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint.

AI tools, transcription & recording

I do not record, transcribe or use AI tools to process therapy or my personal supervision sessions. Neither do I use these tools for administration, writing, planning or education.

Additional Information: Visitors to my website

When someone visits my website, I use a third-party service, WordPress, to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. I do not make, and do not allow WordPress to make any attempt to find out the identities (e.g. IP addresses) of those visiting my website.

I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.

Like most websites, I use cookies to help the site work more efficiently. Cookies are small text files which are stored on your computer or mobile device by a website. This website uses cookies through WordPress. These cookies fall into two categories:

• Essential cookies (these help make a website usable by enabling basic functions like page navigation).
• Statistics cookies (these help website owners understand how visitors interact with websites by collecting and reporting information anonymously).

You can opt out of these non-essential cookies on my website by “Declining” them, this ensures you have the level of choice and consent required by UK law.

You can usually control cookies through your browser settings too.

No user-specific data is collected by me or any third party.

Changes to This Policy

We may update this privacy policy from time to time to reflect changes in our practices or relevant regulations. We will notify you of significant changes by updating the “Last updated” date at the top of this page. Your continued use of our website constitutes your acceptance of the updated policy.