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Privacy Policy

Introduction

Your privacy is very important to me. 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 UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Data (Use and Access) Act. This privacy notice tells you what I will do with your personal information from your initial point of contact through to after your therapy has ended. If you have any questions, you can contact me by email.

The ‘Data controller’ is the term used to describe the person who collects, stores, and takes responsibility for people’s personal data. In this instance, the data controller is me. I am registered with the Information Commissioner’s Office (ICO), reference: ZA783111. My email address is: hello@ianholliscounselling.co.uk


My Lawful Basis for Holding and Using Your Personal Information

The UK 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:

  • Current Clients / Enquiries: If you are currently having therapy or are in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of my contract with you.

  • Special Category Data: Because counselling involves sensitive mental health information, the UK GDPR classifies this as "special category personal data." My lawful basis for processing this is that it is necessary for the provision of health treatment and conducted under a contract with a health professional.

  • Past Clients: If your therapy has ended, I will use legitimate interest as my lawful basis for holding and retaining your personal information for legal, professional indemnity insurance, and clinical record-keeping purposes.

     

How I Use Your Information

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  • Initial Contact: When you enquire about my counselling services, I collect your full name, date of birth, home address, telephone number, email address, GP name/address, emergency contact details, availability, and reasons for seeking support. If you decide not to proceed, all your personal data will be securely deleted within two months, or sooner upon request.

  • While Accessing Counselling: Everything you discuss with me is confidential. Confidentiality will only be broken if I believe there is a significant risk of harm to you or another person, or if there is a strict legal requirement to do so. I will always attempt to speak with you about this first, unless safeguarding or legal restrictions prevent me from doing so.

  • Accounting and Financial Records: For business management and tax compliance purposes, I share my financial records (such as bank statements, invoices, or receipts) with my professional accountant. These documents may contain your name or initials alongside payment records. My accountant is bound by strict professional confidentiality agreements.

  • Professional Continuity (Clinical Will): In accordance with BACP ethical guidelines, I have a "Clinical Will" in place to protect your ongoing support in the event of my sudden illness, incapacitation, or death. I have appointed a trusted, qualified peer counsellor as my Clinical Trustee. This person holds secure, restricted access instructions to my client contact list so they can notify you and manage your ongoing support options if an emergency happens. My Clinical Trustee has absolutely no access to your session notes, and they cannot access your contact details prior to such an incident.

  • Storage and Records: To ensure maximum security, I use WriteUpp as my core practice management software to hold your registration details, appointment logs, and basic communication records. WriteUpp is ISO27001 certified, fully compliant with UK data protection laws, and utilises data encryption and two-factor authentication. Any brief, handwritten clinical session notes I make are held completely separately from your identifying personal details and are stored securely in a physical, lockable filing cabinet accessible only by me. As a BACP registered counsellor, anonymised client themes are shared with my professional supervisor to maintain clinical standards.

  • After Counselling Ends: Once therapy concludes, your electronic record, contact details, and a brief session closure form are securely retained on WriteUpp for one year in case you choose to return, after which they are securely destroyed. Brief clinical notes are held safely in accordance with professional insurance and BACP guidance limitations before permanent deletion.


 

Your Rights

You have the right to ask me to delete your personal information, to limit how I use it, or to stop processing it. You also have a right to request a copy of the information I hold about you (a Subject Access Request). Under current rules, if I require clarification from you regarding a data request, the statutory response timeframe will be paused until you respond. You can read more about your rights on the Information Commissioner’s Office (ICO) website here: https://ico.org.uk. To make a request, please put it in writing to: hello@ianholliscounselling.co.uk


How to Complain

If you have any concerns or complaints about how I handle your personal data, you must raise them with me directly by emailing the address above.
Under the Data (Use and Access) Act, I will formally acknowledge your complaint within 30 days and investigate without undue delay. Please note that UK law requires individuals to attempt to resolve data disputes through my internal complaints procedure before escalating the matter to the regulator.
If you remain dissatisfied after receiving my formal response, you can then escalate a formal complaint to the ICO via their dedicated complaints page here: https://ico.org.uk/make-a-complaint/



Visitors to My Website

My website https://ianholliscounselling.co.uk is hosted by Wix. You can read their full privacy policy directly here: https://www.wix.com/about/privacy. Like most websites, my site uses cookies to help it work efficiently.

  • Essential Cookies: These are automatically used by our hosting platform (Wix) to keep the website secure, prevent cyber attacks, and ensure the page loads quickly.

  • Functional Cookies: These are used to remember your choices, like information you type into my contact forms.

 No user-specific tracking data is collected by me directly.



Changes to This Policy

I may edit this policy occasionally to reflect legislative updates. The latest version will always be displayed on my website.

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