Counselling Privacy Notice
Counselling Privacy Notice
Effective date: 1st June 2026
Last reviewed: 18th June 2026
This privacy notice explains how I collect, use, store and protect personal information when you enter into a counselling relationship with The Separation Specialist.
It should be read alongside the Privacy Notice: Initial Enquiries & Website Use, which explains how information is handled before counselling begins.
Who is responsible for your information
The data controller is:
The Separation Specialist
Robert Cree-Hay
Bramble Lodge, BT203RY
info@separationspecialist.co.uk
+44 28 9146 5073
As data controller, I am responsible for deciding how your personal information is collected, used, stored and protected.
What information I may collect
During counselling, I may collect and process information including:
- your name and contact details;
- date of birth;
- emergency contact details;
- GP details;
- appointment information;
- correspondence relating to counselling;
- brief factual session notes;
- administrative records relating to the counselling relationship;
- information you choose to share about your personal circumstances, relationships, health, emotional wellbeing and life experiences.
Special category information
Counselling frequently involves the discussion of sensitive personal information.
This may include information relating to:
- physical or mental health;
- emotional wellbeing;
- family and relationship circumstances;
- bereavement and loss;
- personal history and life experiences;
- other information considered special category data under UK GDPR.
This information is treated with particular care and protection.
How I collect your information
Information may be collected through:
- counselling sessions;
- telephone conversations;
- Zoom sessions;
- emails and other agreed communications;
- information provided on registration or counselling agreements;
- information provided by you during the course of counselling.
I will normally collect information directly from you.
Why I use your information
I use your information to:
- provide counselling services;
- maintain a safe and effective therapeutic relationship;
- arrange and manage appointments;
- communicate with you regarding counselling;
- maintain appropriate professional records;
- fulfil ethical and professional obligations;
- manage safeguarding, risk and duty of care responsibilities;
- comply with legal, regulatory and insurance requirements.
Counselling and Mediation Boundaries
To ensure clarity, neutrality and professional integrity, I provide either counselling or mediation services to individuals connected with the same circumstances, but not both.
If you enter into a counselling relationship with me, I will not subsequently act as a mediator for you, your partner, former partner, or other participants connected to the same matter.
Similarly, if I have acted as a mediator in relation to a matter, I will not subsequently provide counselling to any participant connected with that mediation.
This boundary helps maintain clear professional roles, protects confidentiality, avoids conflicts of interest, and supports a safe and ethical service for all involved.
My lawful basis for using your information
Under UK GDPR, I must have a lawful basis for processing personal information.
The lawful bases relied upon may include:
Contract
To provide counselling services and manage the counselling relationship.
Legitimate Interests
To operate a safe and effective counselling practice, maintain appropriate records, obtain supervision, manage professional obligations and protect the integrity of the service.
Legal Obligation
Where processing is necessary to comply with legal, safeguarding or regulatory requirements.
Special Category Data
Where counselling involves special category data, processing is carried out for the provision and management of counselling services and in accordance with relevant data protection legislation.
Confidentiality
Confidentiality is an important part of counselling.
Information shared within counselling will normally remain confidential.
However, confidentiality may need to be limited where:
- there is a serious risk of harm to yourself or another person;
- safeguarding concerns arise;
- disclosure is required by law;
- disclosure is required by a court order;
- there is a serious concern regarding criminal activity or public safety.
Where possible and appropriate, I will seek to discuss any necessary disclosure with you beforehand.
Clinical supervision
As part of safe and ethical practice, I participate in professional clinical supervision.
Counselling work may be discussed with a clinical supervisor.
Where possible, identifying information will be minimised and discussions will focus on the counselling work rather than personal identification.
Clinical supervisors are themselves bound by professional and ethical duties of confidentiality.
Who I may share your information with
I do not sell personal information.
Information may be shared only where necessary and appropriate with:
- clinical supervisors;
- professional advisers such as solicitors, accountants or insurers;
- safeguarding authorities;
- emergency services;
- regulatory or legal bodies where required by law.
Any sharing will be limited to what is necessary for the relevant purpose.
Online and telephone counselling
Counselling may be provided:
- in person;
- by telephone;
- via Zoom.
While reasonable steps are taken to maintain privacy and security, no electronic communication system can be guaranteed to be completely secure.
You are encouraged to use private and secure environments when participating in online or telephone counselling.
Record keeping
I maintain appropriate counselling records.
These may include:
- contact and appointment information;
- counselling agreements;
- brief factual session notes;
- administrative records relating to the counselling relationship.
Records are maintained only to the extent necessary for safe, ethical and professional practice.
Retention periods
Counselling records are normally retained for:
Seven years following the end of counselling.
Records may be retained for longer where there is a legal, insurance, safeguarding or professional reason for doing so.
At the end of the retention period, records will be securely deleted or destroyed.
How I keep your information secure
I take reasonable steps to protect personal information from loss, misuse, unauthorised access, disclosure or alteration.
This may include:
- password-protected systems;
- secure electronic storage;
- restricted access to records;
- secure disposal procedures;
- appropriate professional record management.
Your rights
Under UK data protection law, you have rights including the right to:
- be informed about how your information is used;
- request access to your information;
- request correction of inaccurate information;
- request erasure in certain circumstances;
- restrict or object to certain processing activities;
- withdraw consent where consent is being relied upon;
- lodge a complaint with the Information Commissioner’s Office.
Some rights may be limited where professional, legal or safeguarding considerations apply.
If you wish to exercise any of these rights, please contact me using the details above.
Complaints
If you have concerns about how your information has been handled, please contact me in the first instance.
You also have the right to complain to the Information Commissioner’s Office, the UK regulator for data protection matters.
Website: ico.org.uk
Telephone: 0303 123 1113
Changes to this notice
I may update this privacy notice from time to time. The latest version will be available on this website.