Privacy Policy: Counselling and website visitors
This privacy notice tells you what to expect us to do with your personal information.
-
Contact details
-
What information we collect, use, and why
-
Lawful bases and data protection rights
-
Where we get personal information from
-
How long we keep information
-
Who we share information with
-
How to complain
Contact details
clareobrientherapy@outlook.com
What information we collect, use, and why
We collect or use the following information to provide services and goods, including delivery:
-
Names and contact details
-
Addresses
-
Date of birth
-
Purchase or account history
-
Health information (including dietary requirements, allergies and health conditions)
-
Website user information (including user journeys and cookie tracking)
-
Records of meetings and decisions
-
Information relating to compliments or complaints
We also collect or use the following special category information to provide services and goods, including delivery. This information is subject to additional protection due to its sensitive nature:
-
Health information
-
Sex life information
We collect or use the following personal information for dealing with queries, complaints or claims:
-
Names and contact details
-
Address
-
Information relating to health and safety
-
Correspondence
We also collect the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:
-
Health information
-
Sex life information
-
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
-
Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
-
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
-
Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
-
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
-
Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
-
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
-
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide services and goods are:
-
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
-
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
-
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
-
-
I process personal data under legitimate interests for the following purposes: Post-Treatment Record Retention: To retain the records and clinical notes of former clients after our active contract has ended, ensuring I fulfill professional requirements and can respond to any future clinical or legal queries. Practice Defence: To maintain accurate records necessary to meet the terms of my professional indemnity insurance and to defend against any potential civil legal claims or professional complaints. Service Improvement and Website Security: To monitor website visitor traffic and analytics so I can continually improve digital services and maintain data security.
-
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
-
Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
-
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
-
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
-
-
I process personal information under legitimate interests for the following purposes: Responding to Inquiries: To process and reply to initial client queries, contact forms, or booking requests sent via email, phone, or website before a formal contract is established. Complaint Resolution: To review communication histories and process notes if a client raises an issue or lodges a formal complaint with our professional regulatory body (e.g., BACP). Legal Defense and Claims: To maintain and process relevant records required to defend our practice against potential legal actions, civil claims, or disputes, and to share necessary information with our professional indemnity insurer or legal advisors if a claim arises."
-
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Where we get personal information from
-
Directly from you
How long we keep information
Record Category
Retention Period
Lawful Basis
Action at End of Period
Adult Clinical Records
(Intake forms, assessments, brief session summaries)
7 years from the date of the final therapy session.
Legitimate Interest
(Insurance terms & practice defense)
Securely Destroy: Permanent digital wipe or cross-cut shredding.
Financial Records
(Invoices, payment receipts, bank statements)
5 years from the 31 January following the relevant tax year.
Legal Obligation
(HMRC tax compliance)
Securely Destroy: Delete from banking/accounting logs and shred physical copies.
Prospective Inquiries
(Website contact forms, initial emails/logs)
3 to 6 months from the date of the last communication.
Legitimate Interest
(Reasonable follow-up window)
Securely Delete: Purge completely from inbox, trash folders, and device logs.
For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
Who we share information with
Data processors
Email providers, Web hosting, Banking
This data processor does the following activities for us: Email services Website contact form and visitor analytics Receive payment
Others we share personal information with
-
Insurance companies
-
Organisations we need to share information with for safeguarding reasons
-
Professional or legal advisors
-
Relevant regulatory authorities
-
Emergency services
How to complain
If you have any concerns about our use of your personal information, you can make a data protection complaint to us:
Email: clareobrientherapy@outlook.com
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint