Sian Salkeld Counselling customer privacy notice
This privacy notice tells you what to expect us to do with your personal information.
Contact details
Telephone : 07356037611
Email : info@siansalkeldcounselling.com
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
· Names and contact details
· Addresses
· Date of birth
· Third party information (such as family members or other relevant parties)
· Payment details (including card or bank information for transfers and direct debits)
· Transaction data (including details about payments to and from you and details of products and services you have purchased)
· Usage data (including information about how you interact with and use our website, products and services)
· Health information (such as medical records or health conditions)
· Information relating to compliments or complaints
· Website user information
We collect or use the following personal information for the operation of client or customer accounts:
· Names and contact details
· Addresses
· Purchase or service history
· Account information, including registration details
· Information used for security purposes
We collect or use the following personal information for the prevention, detection, investigation or prosecution of crimes:
· Names and contact information
We collect or use the following personal information to comply with legal requirements:
· Name
· Contact information
· Client account information
· Health and safety information
· Any other personal information required to comply with legal obligations
· Safeguarding information
We also collect or use the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:
· Health information
We collect or use the following personal information to protect client welfare:
· Names and contact information
· Client account information
· Health and wellbeing information
· Emergency contact details
We also collect or use the following special category information to protect client welfare. This information is subject to additional protection due to its sensitive nature:
· Health information
We collect or use the following personal information for dealing with queries, complaints or claims:
· Names and contact details
· Addresses
· Payment details
· Account information
· Purchase or service history
· Witness statements and contact details
· Relevant information from previous investigations
· Customer or client accounts and records
· Information relating to health and safety (including incident investigation details and reports and accident book records)
· Correspondence
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 and improve products and services for clients are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· 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 collect and use personal information under the lawful basis of legitimate interests because it is necessary for me to operate a safe, effective, and professionally responsible counselling service. This includes keeping accurate and coherent session notes, managing appointments, monitoring progress, and ensuring continuity of care. These activities directly support the quality of the therapeutic work and help me provide a service that is responsive to each client’s needs. The processing is legitimate because: It enables me to deliver a professional counselling service that meets ethical, clinical, and regulatory expectations. I gain essential insights into a client’s wellbeing, patterns, risks, and therapeutic goals, which directly supports effective treatment planning. Keeping accurate records helps maintain client safety, supports reflective practice, and provides continuity over time. It allows me to improve my service by identifying themes, risks, or adjustments that may be needed to meet a client’s best interests. The processing is necessary because I cannot provide safe, meaningful therapy without understanding a client’s circumstances, history, challenges, progress, and risks. Without these records, I would be unable to provide a consistent service, meet professional obligations, or uphold my duty of care. The benefits outweigh the potential risks because: Processing is minimal and proportionate — I record only what is relevant for therapeutic care, and I avoid unnecessary or excessive information. All information is stored securely on encrypted devices and in private, access‑restricted OneDrive folders. I never use client information for marketing or unrelated activities. Clients are informed about how their information is used, and they can ask questions or exercise their rights at any time. The information is used solely to support their therapeutic process, safeguard their wellbeing, and ensure high‑quality, ethical practice. I do not put my own needs above the client’s. My interest in maintaining good records aligns directly with the client’s interest in receiving safe, effective, and continuous therapy. The processing does not override client rights or freedoms, is not intrusive, and is handled with strict confidentiality.
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 the operation of client or customer accounts are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· 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 rely on legitimate interests to collect and use the personal information needed to operate client accounts because it is essential for running my practice safely, efficiently, and professionally. As a sole practitioner, I must maintain accurate and up‑to‑date records to manage appointments, process payments, maintain account histories, and ensure smooth communication with clients. These activities directly support the day‑to‑day functioning of the therapeutic relationship and allow me to deliver a consistent, reliable, and responsible service. The processing is legitimate because it enables me to: Manage administrative tasks that form a routine and expected part of accessing therapy. Keep accurate financial and attendance records to ensure transparency, continuity, and compliance with professional and ethical standards. Maintain secure client account information that supports clear communication, avoids errors, and ensures that clients receive the service they expect. Protect my practice from administrative problems, such as incorrect billing or missed communications, which could negatively impact clients. The processing is necessary because I cannot operate client accounts safely or reliably without the relevant personal information. This includes contact details, session dates, payment information, and the minimal administrative data required to meet financial, legal, and ethical obligations. The benefits outweigh the risks because: Information collected is limited to what is genuinely needed for account operation; I avoid collecting unnecessary or excessive data. All information is handled confidentially and stored securely using encrypted devices and restricted‑access OneDrive folders. Only I (as the sole practitioner) have access to this information, which significantly reduces risks of misuse or accidental disclosure. The processing supports clients by ensuring their sessions, payments, and communications are handled accurately and professionally. Clients’ rights and freedoms are fully respected, and the information is not used in ways they would not reasonably expect. I do not put my own interests above the client’s. Efficient account operation benefits both the client and my practice, and the processing is proportionate, minimal, and fully aligned with ethical standards and professional responsibilities.
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 the prevention, detection, investigation or prosecution of crimes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· 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 rely on legitimate interests to collect or use personal information where it is necessary to prevent or detect crime, to protect vulnerable individuals, or to cooperate appropriately with lawful investigations. As a counsellor in private practice, I only process the minimum information required and only when it is clearly justified, proportionate, and in the best interests of safety and legal compliance. This processing is legitimate because: It supports the wider public interest in preventing harm, safeguarding individuals, and reducing the risk of criminal activity. It enables me to act responsibly where information suggests a threat to life, serious harm, exploitation, or significant criminal behaviour. It allows me to respond appropriately to enquiries from lawful authorities who are investigating crime, in line with professional ethics and statutory duties. This processing is necessary because: Without using relevant personal information, I would not be able to assess or communicate serious risks, cooperate with lawful investigations, or fulfil my ethical duty to safeguard clients and others. I may need to record and appropriately share limited information that indicates criminal risk (e.g., disclosures of harm to self or others, exploitation, abuse, or serious illegal activity). Appropriate use of this information helps protect clients, third parties, and the public from potential harm. The benefits outweigh the potential risks because: The purpose is strictly protective — to prevent serious harm, protect vulnerable individuals, and uphold legal and ethical obligations. I apply data‑minimisation, recording only what is directly relevant and necessary for risk management, safeguarding, or compliance. I store all information securely, limit access to myself, and only share information when it is essential, proportionate, and legally justified. This processing reduces risk of significant physical, emotional, or social harm to clients or others, which outweighs the minimal privacy impact of documenting or sharing limited information when required. I do not put my own needs above the client’s. Any processing under legitimate interests in relation to crime prevention or investigation serves a protective purpose, prioritising safety, welfare, and legal compliance. It does not involve routine monitoring, unnecessary sharing, or any use that would override the client’s fundamental rights and freedoms.
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 to comply with legal requirements:
· 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 rely on legitimate interests to process certain personal information where doing so supports my ability to meet legal, regulatory, ethical, and professional obligations as a counselling practitioner. Although the primary lawful basis for complying with legal requirements is usually legal obligation, there are occasions where additional, limited processing is necessary to support or evidence compliance. In these situations, the processing serves a legitimate interest that aligns with both my responsibilities and the client’s rights and welfare. This processing is legitimate because: I must operate my practice in a way that is lawful, transparent, and accountable under UK GDPR, the Data Protection Act 2018, and applicable safeguarding and professional‑standards frameworks. I may need to maintain accurate records, document decisions, demonstrate compliance, or manage risk in order to meet my ethical and regulatory duties. Carrying out these activities helps ensure that my practice is safe, professional, and trustworthy, which directly benefits clients. This processing is necessary because: Without collecting or using relevant information, I would be unable to respond appropriately to statutory requests, safeguarding enquiries, professional‑body obligations, tax requirements, or court directions. I may also need to keep limited supporting information to show that I have complied with legal duties (for example, documenting why a disclosure was made, or retaining financial records required by HMRC). The benefits outweigh the potential risks because: Only minimal, strictly necessary information is processed, and only when required to support compliance. Clients benefit from a practitioner who adheres to legal duties, maintains safe practice standards, and can evidence responsible decision‑making. All information is stored securely, with access limited solely to me, and is never shared unless legally justified and proportionate. The processing is protective rather than intrusive, contributing to client safety, fairness, and transparency. I do not put my own needs above the client’s. This processing is undertaken to meet legal requirements that exist to protect clients, uphold professional integrity, ensure accountability, and maintain high standards of practice. It is carefully balanced, proportionate, and designed to respect client rights while fulfilling mandatory obligations.
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 to protect client welfare are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· 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 rely on legitimate interests to collect or use personal information when doing so is necessary to protect the welfare, wellbeing, or safety of my clients. As a counsellor, I have an ethical and professional responsibility to recognise, monitor, and respond appropriately to risks or concerns that may affect a client’s physical or emotional safety. This processing is legitimate because: It enables me to identify, monitor, and respond to wellbeing concerns, safeguarding risks, or changes in a client’s presentation that require therapeutic, ethical, or safety‑related action. It supports the client’s own interests by helping to maintain their safety, continuity of care, and emotional stability. It allows me to make informed professional decisions, such as adjusting therapeutic approaches, offering additional support, or signposting clients to appropriate services when needed. This processing is necessary because: Without collecting and using relevant personal information, I would be unable to understand the client’s needs, track changes in risk, or take steps that protect their wellbeing. Risk assessment, note‑keeping, and careful monitoring are essential parts of providing safe and ethical counselling. In certain situations, I may need to use this information to consult with supervisors or, in rare serious‑risk situations, to protect the client or another person. The benefits outweigh the potential risks because: I only collect the minimum information required to support and protect the client’s welfare, and I avoid unnecessary or intrusive details. All information is stored securely, accessed only by me, and never used for purposes unrelated to client care or safety. This processing reduces the likelihood of harm, ensures continuity of care, and supports therapeutic progress—benefits which significantly outweigh the limited privacy impact of proportionate record‑keeping. Clients’ rights and dignity are always respected, and information is handled with strict confidentiality unless there is a compelling safety‑based reason to act. I do not put my own needs above the client’s. The purpose of this processing is solely to support the client’s welfare, protect their wellbeing, and uphold my ethical duty of care. All decisions are made with the client’s best interests as the priority, and any impact on their privacy is kept to the minimum necessary to safeguard them effectively.
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:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· 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 rely on legitimate interests to collect or use personal information when responding to queries, handling complaints, or addressing potential claims. As a sole‑practitioner counsellor, I must manage communications professionally, maintain accurate records, and resolve concerns in a way that supports fairness, transparency, and high‑quality therapeutic practice. This processing is legitimate because: It enables me to respond appropriately to client enquiries, clarify misunderstandings, and address concerns in a way that protects the integrity of the therapeutic relationship. It supports both my interests and the client’s in ensuring accurate communication, resolving issues promptly, and maintaining clear and accountable records. Where a complaint or claim is raised, I must review relevant information to understand what happened, provide an accurate response, and comply with legal, ethical, or professional‑body procedures. This processing is necessary because: Without using relevant personal information, I would be unable to investigate the issue, understand the context, or give a fair, complete, and evidence‑based response. Accurate record‑keeping is essential for resolving disputes, defending against unfounded claims, or complying with insurance and regulatory expectations. It allows me to demonstrate responsible practice, ensure high standards of care, and maintain trust in my service. The benefits outweigh the potential risks because: I only process the minimum information required to understand and resolve the query or concern. Clients benefit directly from having their issues addressed fairly, transparently, and with appropriate reference to the facts. All information is handled confidentially, stored securely, and only used for the purpose of resolving the specific issue. This processing helps prevent escalation, reduces misunderstandings, and supports both client welfare and the integrity of my practice. I do not put my own needs above the client’s. My aim is to handle queries and complaints in a way that is balanced, respectful, and centred on good practice. Any processing is proportionate, limited to what is necessary, and focused on ensuring fair treatment for the client while meeting my ethical, legal, and professional obligations.
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.
Where we get personal information from
· Directly from you
How long we keep information
Data Retention Schedule
Clinical Records (Session Notes, Assessments, Treatment Plans)
Retention Period:
7 years from the date of last contact.
Minors: Retain until age 25, or 26 if they were 17 when therapy ended.
Justification:
Required for legal defence, insurance compliance, and professional standards.
Supports safe, continuous therapeutic practice.
Disposal:
Secure deletion or irreversible anonymisation.
Client Contact Information
Retention Period:
While active, plus 1 year after therapy ends.
Justification:
Necessary for communication, scheduling, and follow‑up.
Minimisation recommended by BACP.
Disposal:
Delete unless legally tied to clinical, financial, or complaint files.
Contracts, Consent Forms, Privacy Notices
Retention Period:
Mirror clinical records:
7 years (adults)
Until age 25/26 (minors)
Justification:
Evidential documents required for legal or insurance purposes.
Disposal:
Secure deletion.
Emails and Written Client Communications
Retention Period:
1 year unless clinically relevant.
Clinically relevant correspondence retained with clinical notes for 7 years.
Disposal:
Delete non‑clinical communications after 1 year.
Extract and store relevant information in core clinical record if needed.
Financial Records (Invoices, Payments, Receipts)
Retention Period:
6 years, in accordance with HMRC requirements.
Justification:
Legally required for tax documentation and audit.
ICO: retention must reflect legal obligations.
Disposal:
Secure deletion.
Complaints, Claims, and Professional Conduct Files
Retention Period:
7 years from closure of the matter.
Matches insurer evidence requirements and legal limitation periods.
Complaints may be submitted for up to 3 years, so extended retention protects against late claims.
Disposal:
Secure deletion.
Supervision Notes (Containing Client Identifiers)
Retention Period:
7 years, unless immediately anonymised.
Disposal:
Delete or anonymise once retention period ends.
Prospective Client Enquiries (Where Therapy Does Not Proceed)
Retention Period:
6 months from last contact.
In line with GDPR minimisation and purpose-based storage.
Disposal:
Delete.
Backups, Duplicates, and Archived Versions
Retention Period:
Must match the retention period of the original record.
Ensure that deletion applies across systems and backups.
Disposal:
Secure digital erasure and/or anonymisation.
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
Others we share personal information with
· Professional or legal advisors
· Emergency services
· Organisations we’re legally obliged to share personal information with
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
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
