Privacy Policy

Your privacy is very important to me and you can be confident that 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 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 I will do with your personal information from initial point of contact through to after your therapy has ended, including:

• Why I am able to process your information and what purpose I am processing it for

• Whether you have to provide it to me

• How long I store it for

• Whether there are other recipients of your personal information

• Whether I intend to transfer it to another country

• Whether I do automated decision-making or profiling

• Your data protection rights

I am happy to chat through any questions you might have about my data protection policy and you can contact me via hello@michelmacounselling.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 me. I am registered with the Information Commissioner’s Office (ICO)(registration number: ZC270289).

My lawful basis for holding and using your personal information

The 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: 

If you have had therapy with me and it has now ended, I will use legitimate interest as my lawful basis for holding and using your personal information. 

If you are currently having therapy or if you are in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of our contract. 

The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for me processing any special categories of personal information is consent initially. I will then retain any counselling records in case of the need to reference them in the future (the official legal basis is to defend against potential legal claims).

How I use your information

Initial contact

When you contact me with an enquiry about my counselling services I will collect information to help me satisfy your enquiry. This will include your name, your email address, and your contact number. 

If you decide not to proceed I will ensure all your personal data is deleted within 3 months. If you would like me to delete this information sooner, just let me know.

While you are accessing counselling

Everything you discuss with me is treated as confidential. However, there may be circumstances in which I need to share information without your consent. This may be necessary if I believe you or someone else is at risk of serious harm, if I have safeguarding concerns involving a child or an adult at risk, or if disclosure is required or permitted by law. This may also include situations involving the prevention or detection of serious crime, such as terrorism or serious financial crime. Where appropriate and safe to do so, I will aim to discuss this with you before sharing any information, unless doing so could increase the risk of harm or compromise safeguarding.

I keep a record of your personal details to manage our counselling arrangements, such as scheduling sessions and processing payments. I also keep brief notes of our sessions to support our work together and meet my professional responsibilities.

I use Google Workspace for practice-related activities, such as email and communication. Your counselling notes are stored separately on a password-protected device with additional password protection. I take appropriate steps to protect your personal information and keep it secure.

For security and data minimisation purposes, I delete routine email correspondence after one year unless it needs to be retained for professional, legal or administrative reasons. Any correspondence that needs to be kept is stored securely and retained only for as long as necessary.

After counselling has ended

After our counselling work has ended, I will retain your records for three years from the end of our contact, after which they will be securely destroyed. If you would like your information to be deleted sooner, please contact me. I will consider your request in accordance with my legal and professional responsibilities, as I may need to retain certain records for a specific period.

Third party recipients of personal data

I use trusted third-party service providers to support the running of my counselling practice. These providers may process personal information on my behalf when providing services such as email and communication.

I use Google Workspace for practice-related activities, including email and communication. Google may process personal data as part of providing and maintaining these services. However, I do not store counselling session notes on Google Workspace or other Google services.

Where a third-party provider processes personal data on my behalf, I take reasonable steps to ensure that appropriate data protection arrangements are in place. This includes checking how the provider handles personal information and, where required, ensuring that a suitable data processing agreement is in place.

I do not sell your personal information. I only share personal data where necessary for the purposes described in this privacy policy, or where disclosure is required or permitted by law. Some service providers may process or store personal data outside the UK. Where this happens, I will ensure that appropriate safeguards are in place in accordance with applicable data protection law.

Your rights

I try to be as open as I can be in terms of giving people access to their personal information. You have a right to ask me to delete your personal information, to limit how I use your personal information, or to stop processing your personal information. You also have a right to ask for a copy of any information that I hold 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 I do hold information about you I will:

• give you a description of it and where it came from;

• tell you why I am holding it, tell you how long I will store your data and how I made this decision;

• tell you who it could be disclosed to;

• let you have a copy of the information in an intelligible form.

You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you. To make a request for any personal information I may hold about you, please put the request in writing addressing it to hello@michelmacounselling.co.uk.

If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by writing or emailing to the contact details given above. I would welcome any suggestions for improving my data protection procedures. If you want to make a formal complaint about the way I have processed your personal information 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

I take the security of the personal information I hold about you seriously and take appropriate steps to keep it safe and prevent unauthorised access, loss or disclosure. My phone and computer are password-protected, and I protect individual counselling notes with a separate password in the Notes app on my phone. I use Google Workspace for practice-related activities, including email and communication, and take care to protect access to my account.

I only collect and retain personal information that is necessary for my counselling practice. I also take care when handling, storing and disposing of your information to maintain its confidentiality. While I take reasonable steps to protect your personal information, no method of electronic storage or transmission is completely secure. If a personal data breach occurs, I will respond appropriately and take any necessary steps in accordance with applicable data protection requirements.