Introduction 

Your privacy is very important to Clarity Counselling, Wellbeing & Coaching, and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose for which it was given. 

We 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 is done with your personal information from initial point of contact through to after your therapy has ended, including: 

• Why we are able to process your information and what purpose it is processed for
• Whether you have to provide the information
• How long it is stored
• Whether there are other recipients of your personal information
• Whether it will be transferred to another country,
• Whether there is automated decision-making or profiling, and
• Your data protection rights.

You are welcome to chat through any questions you might have about our data protection policy and you can contact us via enquiries@claritycwc.co.uk.

‘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 Debra Sparshott, registered with the Information Commissioner’s Office; reference number: ZA267557.

Lawful basis for holding and using your personal information 

The GDPR states that there must be a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which your data is being processed. These are explained below: 

If you have had therapy with Clarity Counselling, Wellbeing & Coaching and it has now ended, legitimate interest will be used as the lawful basis for holding and using your personal information. 

If you are currently having therapy or if you are in contact with Clarity Counselling, Wellbeing & Coaching to consider therapy, your personal data will be processed where it is necessary for the performance of our contract. 

The GDPR also makes sure that any sensitive personal information that you may disclose is handled appropriately. This type of information is called ‘special category personal information’. The lawful basis for any special categories of personal information being processed is initial consent. Retention of any counselling records in case of the need to reference them in the future will be on the official legal basis of defence against potential legal claims.

How use your information is used 

How it might look 

Initial contact. 

When you contact Clarity Counselling, Wellbeing & Coaching with an enquiry about one of our counselling, training or coaching services, information is collected to enable an appropriate response to your enquiry. This will include your name, email address, telephone number and address. 

Alternatively, your GP or other health professional may send your details when making a referral, or a parent or trusted individual may provide your details when making an enquiry on your behalf. 

If you decide not to proceed all your personal data is deleted within 28 days. If you would like this information to be deleted sooner, please contact enquiries@claritycwc.co.uk.

While you are accessing counselling. 

Everything you discuss is confidential. That confidentiality will only be broken if there is deemed to be serious risk of harm to you or to someone else. Effort is made to speak to you about this first, unless there are safeguarding issues that prevent this.

A record of your personal details will be kept to support the smooth provision of counselling services. These details are kept securely on encrypted devices or in a locked filing cabinet, and are not shared with any third party. Written notes are made of each session, these are kept in a locked filing cabinet. For security reasons text messages are not kept for more than 28 days. If there is relevant information contained in a text message it will be retain in a printed copy with the written notes. Likewise, any email correspondence will be deleted after 28 days if it is not important. If necessary, a printed copy will be retained with the written notes.

After counselling has ended. 

Once counselling has ended your data will be kept for two years from the end of our contact with each other and are then securely destroyed. If you want your information to be deleted sooner than this, please contact enquiries@claritycwc.co.uk.

Third party recipients of personal data 

How it might look 

Personal data is sometimes shared with third parties, where a carefully selected supplier has been contracted to carry out specific tasks. Great care is taken to ensure their contract states what they are allowed to do with the data shared with them, and that they do not use your information in any way other than the task for which they have been contracted.

Your rights 

How it might look 

We try to be as open as possible in terms of giving people access to their personal information. You have a right to request that your personal information is deleted, to limit how it is, or to stop the processing of it. You also have a right to ask for a copy of any information that is held 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 information is held about you, Clarity Counselling, Wellbeing and Coaching will:: 

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

You can also ask at any time for the correction of any mistakes there may be in the personal information held about you. To make a request for any personal information held about you, please put the request in writing to enquiries@claritycwc.co.uk.

If you have any complaint about how your personal data is handled please do not hesitate to get in touch via the email address given above. Any suggestions for the improvement of our data protection procedures are welcome. If you want to make a formal complaint about the way your personal information is processed 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.

Data security 

How it might look 

Data security is taken very seriously, and every effort is taken to make sure it is kept secure. Personal information is stored securely on encrypted devices and in a locked filing cabinet.

Visitors to my website 

When someone visits the Clarity Counselling, Wellbeing & Coaching website, a third party service, Ionos Inc. is used to collect standard internet log information and details of visitor behaviour patterns. This is done to monitor use of the site, e.g. data 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. There is no attempt by either Clarity Counselling, Wellbeing & Coaching, or Ionos Inc. to find out the identities of those visiting the website. Legitimate interests is used as the lawful basis for holding and using your personal information in this way when you visit the website. 

Ionos Inc. is used to continually improve our service. You can read their privacy policy here. As with most websites third-party website tracking technologies are used to provide and continually improve our services. 

I agree and may revoke or change my consent at any time with effect for the future. No user-specific data is collected by Clarity Counselling, Wellbeing & Coaching, or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to Clarity Counselling, Wellbeing & Coaching.