Privacy Policy

1. Introduction

In my counselling work, I act as the Data Controller. This means I am responsible for deciding how your personal information is collected, used, stored and, where necessary, securely destroyed.

Processing includes the organisation, retrieval, consultation, use, storage, disclosure and secure destruction of information.

I am committed to protecting your privacy and handling your information with care, respect and confidentiality. Your personal information is only used where there is a clear and lawful reason to do so.

2. What personal information I may collect

The information I collect will depend on the nature of your enquiry, assessment or counselling work. This may include:

Type of information	Examples
Contact details	Name, email address, telephone number, address and emergency contact details.
Personal details	Date of birth, family information, relationship status or relevant background information.
Counselling information	Assessment information, session notes, presenting issues, goals, risks, progress and therapeutic themes.
Health and wellbeing information	Information about mental health, physical health, medication, GP details or other professionals involved in your care.
Administrative information	Appointment records, attendance, payments, signed agreements, correspondence and consent records.
Safeguarding or risk-related information	Information relating to risk of harm to yourself, a child, a vulnerable adult or another person.

Some information shared in counselling may be classed as special category data, particularly where it relates to physical or mental health. This type of information is given additional protection under data protection law.

3. Why I use your personal information

The main reason I use your personal information is to provide a safe, ethical and professional counselling service.

Purpose	Why this is needed
Respond to enquiries	To reply to your initial contact and provide relevant information about counselling.
Assess your needs	To understand whether counselling with me is appropriate and safe.
Provide counselling	To support the therapeutic work we agree to undertake together.
Maintain records	To keep accurate, professional and ethical records of the service provided.
Manage appointments and communication	To arrange sessions, respond to messages and provide service-related information.
Support professional supervision	To reflect on my work and maintain ethical and professional standards.
Respond to complaints or concerns	To investigate and respond appropriately if a concern is raised.
Meet legal, professional or insurance obligations	To comply with statutory duties, professional responsibilities, insurance requirements and risk management.

I do not use your personal information for marketing purposes.

4. Lawful basis for processing your information

Data protection law requires me to have a lawful basis for using your personal information.

The main lawful basis I rely on is that processing your information is necessary for the counselling contract between us. This includes responding to your enquiry, assessing your needs, providing counselling and maintaining appropriate records.

Where information relates to your physical or mental health, it may be classed as special category data. This information is processed only where there is an appropriate lawful basis and a relevant special category condition under UK data protection law.

Type of processing	Lawful basis
Providing counselling services	Necessary for the performance of a contract.
Maintaining professional records	Contractual necessity, legal obligations, professional obligations and legitimate interests.
Processing health or wellbeing information	Necessary for the provision of counselling, care, risk management and/or with explicit consent where applicable.
Safeguarding or serious risk concerns	Vital interests, legal obligations and/or substantial public interest where relevant.
Responding to legal requests or court orders	Legal obligation.

5. Confidentiality

I keep information about you strictly confidential. This means I store it securely and control who has access to it.

Confidentiality is an important part of counselling. However, it is not absolute. There may be rare circumstances where I need to share information without your consent, particularly where there is a serious concern about safety, legal duty or risk.

6. Professional supervision

As part of ethical counselling practice, I may discuss aspects of my work with a professional supervisor. This helps me reflect on my practice and ensure I am working safely and ethically.

When I discuss client work in supervision, I do so in a way that protects your identity. Information is shared anonymously wherever possible, and you will not usually be identifiable from this process.

7. When information may be shared

I will only share information where there is a clear and necessary reason to do so. I will only share the minimum information needed and only with individuals or organisations who are entitled to receive it.

Situation	Possible reason for sharing
Risk of serious harm	To protect you, a child, a vulnerable adult or another person.
Safeguarding concerns	To meet safeguarding duties and protect those at risk.
Prevention or detection of crime	Where disclosure is necessary for the prevention or detection of a serious crime.
Court order or legal requirement	Where I am legally required to provide information.
Medical or professional concerns	In exceptional circumstances, where further information may be needed from a GP or another medical professional.
Complaint, legal claim or insurance matter	To respond appropriately to complaints, claims, audits or professional obligations.

Where possible and appropriate, I will discuss this with you before sharing information. However, there may be situations where this is not possible, for example where doing so could increase risk or where I am legally required to act.

8. Contact with your GP or other professionals

In exceptional circumstances, I may need to request information from your GP or another medical professional. This would usually only happen where it is relevant to your safety, wellbeing or the suitability of counselling.

Where appropriate, I will seek your consent before contacting another professional. However, if there is a serious and immediate risk, I may need to act without your consent in order to protect you or another person.

9. How your information is stored

Your information is stored securely and handled with care.

Counselling records and related information may be stored in a locked filing cabinet and/or securely within password-protected digital systems where relevant. Access is restricted and information is not shared unless there is a clear and lawful reason to do so.

I take reasonable steps to protect your information from unauthorised access, loss, misuse or disclosure.

10. How long your information is kept

Counselling records are kept for no less than seven years after the counselling work ends.

In some circumstances, records may be kept for longer. This may depend on factors such as legal requirements, insurance obligations, professional guidance, safeguarding considerations, complaints, audits, risk management, archiving requirements or if you return to counselling at a later date.

Type of record	Typical retention period
Counselling notes and client records	No less than seven years after counselling ends.
Signed counselling agreement and consent records	No less than seven years after counselling ends.
Administrative correspondence	Kept only for as long as necessary.
Safeguarding, complaint or legal records	May be kept for longer where required.

When records are no longer required, they will be securely destroyed.

11. Accuracy of information

I aim to keep the information I hold about you accurate and up to date.

If you believe any information I hold about you is incorrect, incomplete or out of date, please contact me so this can be reviewed and, where appropriate, corrected.

12. Your data protection rights

Under data protection law, you have rights in relation to your personal information. These rights may include:

Your right	What this means
Right to be informed	You have the right to know how your information is collected and used.
Right of access	You can ask for a copy of the personal information held about you.
Right to rectification	You can ask for inaccurate or incomplete information to be corrected.
Right to erasure	You can ask for your personal information to be deleted in certain circumstances.
Right to restriction	You can ask for the use of your information to be restricted in certain circumstances.
Right to object	You can object to certain types of processing.
Right to data portability	You may have the right to receive certain information in a reusable format.

These rights are not absolute and may depend on the lawful basis for processing, professional obligations, legal requirements, insurance requirements, safeguarding concerns or other valid reasons for retaining information.

13. Requests to delete information

If you would like your personal information to be deleted, please contact me.

I will take reasonable steps to remove your information where I am able to do so. However, it may not always be possible to delete all information, particularly where I need to keep it for legal, insurance, safeguarding, auditing, internal risk management, professional or archiving purposes.

14. Concerns or complaints

If you have any concerns about how your personal information is being handled, please contact me in the first instance:

Leon Francis
Email: leonfranciscounselling@gmail.com

You also have the right to contact the Information Commissioner’s Office, which is the UK’s independent authority for data protection matters.

Information Commissioner’s Office: https://ico.org.uk/

15. Consent and agreement

By entering into counselling with me, you acknowledge that you have read and understood this Privacy Policy and that your personal information will be used as described.

You have the right to ask for your information to be amended or deleted, although it may not always be possible to delete all information where there is a valid reason for it to be retained.