1. Introduction

I am committed to protecting your privacy and handling your personal information with care, respect and confidentiality.

This privacy notice explains how I collect, use, store, protect and share your personal information when you contact me, enquire about counselling or supervision attend sessions or otherwise engage with my counselling and supervision services.

I aim to handle your information in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (PECR), as applicable, and the British Association for Counselling and Psychotherapy (BACP) Ethical Framework for the Counselling Professions.

Confidentiality is an essential part of the therapeutic relationship. I will respect your privacy and explain any foreseeable limitations to confidentiality before or at the beginning of our work together.

2. Who I am and how to contact me

Practice name: Jacqueline Moran Counselling and Psychotherapy 
Email: jacquelinemorancounselling@outlook.com
Telephone: 07508 773819
Website: www.jacquelinemoran.co.uk
ICO registration number: ZA329450

I am the data controller for the personal information I collect and use in connection with my independent counselling and supervision practice, unless otherwise explained to you.

If you have questions about this notice, how I handle your information, or your data protection rights, please contact me using the details above.

3. What personal information I collect

Depending on your contact with me and the services you receive, I may collect and process the following information:

• Identity and contact details: your name, date of birth where necessary, address, telephone number and email address.
• Enquiry and appointment information: information you provide when making an enquiry, arranging appointments, cancelling sessions or discussing practical arrangements.
• Counselling information: relevant personal history, your reasons for seeking counselling, information discussed during sessions, progress notes and other records necessary to provide a safe and appropriate service.
• Special category personal data: information about your physical or mental health and emotional wellbeing.
• Emergency and safeguarding information: details of an emergency contact, where appropriate, and information relevant to assessing or responding to a serious risk of harm.
• Payment and administrative information: records of payments, invoices and other information necessary for accounting and business administration.
• Electronic communications and website information: emails, text messages, online session details, technical information and cookie data, where applicable.

I aim to collect only information that is relevant and necessary for providing counselling and supervision, meeting my professional responsibilities and complying with legal obligations.

4. Why I use your information

I use your personal information for the following purposes:

• Responding to enquiries and deciding whether my service is appropriate for your needs.
• Arranging and providing counselling and supervision sessions.
• Maintaining appropriate clinical and administrative records.
• Supporting your safety and wellbeing and meeting safeguarding responsibilities.
• Discussing my work with an appropriately qualified supervisor to maintain professional standards.
• Managing appointments, payments, cancellations and correspondence.
• Meeting relevant legal, regulatory, insurance and professional obligations.
• Maintaining the security and proper functioning of my communications systems and website.

I will not use your personal information for unrelated purposes that are incompatible with the reasons for which it was collected.

5. My lawful basis for processing your information

Data protection law requires me to identify a lawful basis for processing personal data and an additional condition for processing special category data, such as health information.

Depending on the purpose and circumstances, I may rely on the following lawful bases:

• Legitimate interests: where necessary for legitimate business or professional interests, provided these are not overridden by your rights and interests.
• Legal obligation: where I must process information to comply with a legal requirement.
• Vital interests: where processing is necessary to protect someone's life in circumstances permitted by law.

I will not assume that your agreement to counselling or supervision automatically constitutes consent to every form of data processing. Where consent is the appropriate legal basis, I will explain what is being requested and how you can withdraw it.

 

6. Confidentiality and its limits

What you share in counselling will normally be treated as confidential. I will not routinely disclose identifiable information about you to other people or organisations without your permission or another valid legal and ethical justification.

However, confidentiality is not absolute. Information may need to be shared where:

• There is a serious and sufficiently credible risk of significant harm to you or another person.
• There are safeguarding concerns involving a child or an adult at risk, requiring action under applicable law or safeguarding procedures.
• Disclosure is required by a court order or another binding legal obligation, or is otherwise lawfully authorised.
• Sharing is necessary and justified to address another serious legal or ethical concern.

Where appropriate and safe to do so, I will discuss the situation with you before disclosing information. I will consider the circumstances carefully, seek appropriate professional or legal advice where necessary, and disclose only information that is relevant and proportionate to the purpose.

I cannot guarantee that I will always be able to notify you before a disclosure, particularly where doing so could increase the risk of harm or prejudice a lawful investigation.

7. Supervision and professional consultation

As part of maintaining a safe and ethical counselling and supervision practice, I discuss my work with a professional supervisor.

Where possible, I use anonymised or de-identified information. If identifiable information needs to be discussed, I will handle it in accordance with my confidentiality agreement, applicable data protection law and the arrangements explained to you.

8. Who may receive your information

I do not sell your personal information or share counselling records for advertising purposes.

Where necessary and justified, information may be shared with:

• My professional supervisor.
• Relevant safeguarding services, emergency services, healthcare professionals or other appropriate organisations where a lawful and ethical basis for disclosure exists.
• My professional indemnity insurer, legal adviser or relevant professional body where necessary and justified.
• Courts, regulators or public authorities where required or lawfully authorised.

I will not disclose your information to family members, employers or other third parties simply because they request it.

 

9. How I store and protect your information

I take appropriate technical and organisational measures to protect your information against unauthorised access, loss, alteration, misuse or disclosure.

These measures may include:

• Password-protected and access-controlled devices and accounts.
• Secure storage of electronic records.
• Locked storage for paper records.
• Confidential disposal of documents and deletion of electronic records when appropriate.
• Limiting access to information to those who need it for a legitimate purpose.
• Using suitable security measures when communicating or conducting online sessions.

No method of electronic communication or data storage can be guaranteed to be completely secure. I will nevertheless take reasonable and proportionate steps to protect your information and respond appropriately to any suspected data breach.

10. Email, telephone, text messages and online counselling

I may use email, telephone, text messages or an online video platform to communicate with you or provide counselling or supervision, depending on the arrangements agreed.

Electronic communications can carry privacy risks. For example, emails and text messages may be accessed by other people with access to your device or account, and online platforms may process technical information.

Please consider whether your email address, telephone number, voicemail or device is safe for confidential communications. I will use your contact details for appropriate practice-related communications and will not use them for unsolicited marketing without a lawful basis and any consent required by PECR.

Online sessions will be conducted using the agreed platform. I will not record sessions.

11. How long I keep your information

I retain personal information only for as long as is reasonably necessary for the purpose for which it was collected, taking account of my professional responsibilities, legal obligations, insurance requirements and any need to establish or defend legal claims. My liability insurers instruct me to store counselling and supervision notes for five years.

When information is no longer required, I will securely delete it as appropriate, unless there is a lawful reason to retain it for longer.

If you stop attending counselling or supervision and ask for your records to be deleted, I will consider your request in accordance with applicable law and my professional and legal responsibilities. I may need to retain some information for an appropriate period.

 

12. Your data protection rights

Subject to the conditions and exemptions provided by law, you may have the right to:

• Access: request a copy of the personal information I hold about you.
• Rectification: ask me to correct inaccurate or incomplete information.
• Erasure: request deletion of your personal information where the legal conditions are met.
• Restriction: ask me to restrict the processing of your information in certain circumstances.
• Objection: object to processing carried out on the basis of legitimate interests or for direct marketing, where applicable.
• Data portability: request certain information in a commonly used electronic format where the legal conditions apply.
• Withdraw consent: where processing is based on consent, withdraw it at any time. This does not affect the lawfulness of processing carried out before withdrawal.

These rights are not absolute, and certain exemptions may apply to counselling records or information that must be retained for legal or professional reasons.

To exercise a right, please contact me using the details in Section 2. I may need to verify your identity before responding. I will normally respond within one month of receiving a valid request, subject to any lawful extension or other applicable requirements.

13. Complaints and concerns

If you have concerns about how I handle your personal information, please contact me first so that I can try to resolve the matter.

You also have the right to complain to the UK Information Commissioner's Office (ICO), which oversees data protection in the UK.

Website: https://ico.org.uk/
Telephone: 0303 123 1113

You may also raise a concern about professional conduct through the appropriate BACP procedures where relevant.

14. Changes to this privacy notice

I may update this notice to reflect changes in my practice, the information I collect, the services I use or relevant legal and professional requirements.

The current version will be made available to clients and supervisees, and I will communicate significant changes where appropriate.

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