Clay Counselling Privacy Notice
Last Updated: August 2026
Your privacy is very important to me. You can be confident that your personal information will be kept safe, secure and used only for the purpose for which it was provided. I comply with UK data protection legislation including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR).
This privacy notice explains what personal information I collect, how I use it, how long I keep it, who it may be shared with, and your rights in relation to that information.
Data controller
Clay Counselling is the data controller for the personal information described in this notice.
- ICO registration number: ZA623601
- Email: admin@claycounselling.co.uk
- Website: www.claycounselling.co.uk
If you have any questions about this notice or about how your information is handled, please contact me using the details above.
What information I collect
The information I collect depends on whether you are making an enquiry, attending an initial consultation, or receiving counselling.
Initial enquiries
When you contact me by email, telephone, text message, website form or other means, I may collect:
- your name
- telephone number
- email address
- a brief outline of the reason for your enquiry
- your preferred method of contact
I collect only the information necessary to respond to your enquiry.
If you attend an initial consultation
I may also collect:
- postal address
- date of birth
- GP details
- emergency contact details
- relevant health, wellbeing and personal history information
- any assessment questionnaires completed
While you are receiving counselling
I may keep:
- appointment records
- brief session notes
- risk or safeguarding information where relevant
- correspondence relating to appointments or therapy
- payment and invoicing records
Session notes are kept separately from your contact details wherever possible and do not routinely include unnecessary identifying information.
My lawful basis for processing your information
Under UK GDPR I must have a lawful basis for processing your personal data.
Enquiries and arranging appointments
Lawful basis: Legitimate interests (responding to requests for counselling and managing appointments).
Providing counselling
Lawful basis: Performance of a contract (providing the counselling service requested).
Special category information (health and therapy information)
Information about your health, mental health, sexuality, relationships or other sensitive matters is classed as special category data.
Lawful basis: Provision of health/social care and counselling services, together with your explicit consent where appropriate.
Retaining records after therapy has ended
Lawful basis: Legitimate interests and the establishment, exercise or defence of legal claims.
You are not legally required to provide personal information, but if you choose not to provide information that is necessary for counselling, I may be unable to offer a service.
Confidentiality
Everything discussed in counselling is treated as confidential. Confidentiality may be broken where:
- there is a serious and imminent risk of harm to you or another person,
- there are safeguarding concerns involving a child or vulnerable adult,
- I am required to do so by law or court order, or
- disclosure is otherwise permitted by law.
Where possible, I will discuss any proposed disclosure with you first unless doing so would increase risk or is prohibited by law.
How your information is stored
I take the security of your information seriously.
Paper records
Paper records are stored in locked filing cabinets within a locked counselling office.
Electronic records
Electronic information is stored on password-protected devices. Devices used for counselling administration are protected by passcodes and security software and are kept securely.
Email and messaging
Email and text messaging are not completely secure methods of communication. Please avoid sending highly sensitive information by email or text unless necessary.
How long I keep information
I keep records only for as long as necessary for the purposes described above.
Record type | Retention period |
Initial enquiry where therapy does not proceed | 3 months from last contact |
Initial consultation notes where therapy does not proceed | 1 year from consultation date |
Client contact details | Duration of therapy and then archived with client record |
Session notes and clinical records | 7 years from the end of therapy |
Supervision records containing anonymised client material | 7 years |
Email correspondence relating to therapy | 12 months after therapy ends unless clinically relevant |
Text/WhatsApp messages relating to appointments | 3 months after therapy ends unless clinically relevant |
Voicemail messages | Deleted once actioned, normally within 1 month |
Invoices, receipts, accounts and tax records | 6 years plus the current tax year in accordance with HMRC requirements |
At the end of the relevant retention period, paper records are shredded and electronic records are securely deleted.
If you contact me but do not become a client
If you make an enquiry and decide not to proceed, or if I am unable to offer you an appointment, your enquiry information will normally be deleted within 3 months of our last contact. You may request earlier deletion.
If you attend an initial consultation but counselling does not begin, I may retain a brief record of that consultation for up to 1 year in case of later queries or professional issues.
Third parties who may receive information
I do not sell or share your personal information for marketing purposes.
I may share limited information with third parties only where necessary, for example:
- Clinical supervisor – anonymised clinical discussion for professional supervision.
- GP or other healthcare professional – only with your consent unless disclosure is required by law or necessary to prevent serious harm.
- Accountant or HMRC – financial records where legally required.
- IT, email, website hosting or administrative service providers – where they process data on my behalf under appropriate data protection agreements.
I take care to use service providers that provide appropriate security and confidentiality protections.
Information received from third parties
On occasion I may receive information about a client from a third party, such as a family member, partner, healthcare professional, or other individual. I will consider whether the information is relevant to the provision of counselling, safeguarding, risk management, or my professional obligations. Irrelevant information will be deleted as soon as reasonably practicable. Relevant information may be retained with the client’s records for the same retention period as those records.
Online and telephone counselling
Video counselling
I usually use Google Meet or Zoom for online counselling sessions. Google Meet is provided by Google and Zoom is provided by Zoom Video Communications, Inc. Each provider acts as a separate data controller for some information processed through its platform.
Information about their privacy and security practices can be found here:
- Google Meet: https://support.google.com/meet/answer/9852160
- Zoom: https://www.zoom.us/privacy
By choosing online counselling, you acknowledge that internet-based communication carries some security risks, although reasonable steps are taken to minimise these risks.
Telephone counselling
Calls may be made using a mobile or landline telephone. Your number may appear in call logs for a limited period but is not routinely stored in my contacts unless necessary for ongoing therapy.
Recording
Neither you nor I may audio-record or video-record counselling sessions without prior written agreement.
International transfers
Some technology providers used for email, video conferencing or website services may process data outside the UK. Where this occurs, I seek to ensure that appropriate safeguards are in place, such as UK adequacy regulations or approved contractual safeguards.
Automated decision-making
I do not use automated decision-making or profiling in relation to your personal information.
Website and cookies
My website is built using WordPress. Like most websites, it uses cookies that are necessary for the operation of the site. WordPress may automatically place certain standard cookies on your device to support functions such as page display, security and basic website operation.
I do not personally analyse cookie data or use cookies to profile visitors or monitor their behaviour. I do not currently use website analytics to identify visitors or track how individuals use the site.
When you visit the website, a cookie notice is displayed to inform you that cookies are used. The notice can be closed or acknowledged by clicking the button provided. This notice is informational and does not currently offer separate cookie preference options.
The website host may collect standard technical information such as IP address, browser type and pages visited for security and website administration purposes. This information is not used by me to identify individual visitors.
My website may contain links to other websites. I am not responsible for the privacy practices of those websites.
Your rights
You have rights under UK data protection law, including the right to:
- access a copy of your personal information,
- ask for inaccurate information to be corrected,
- request erasure of information in certain circumstances,
- restrict processing in certain circumstances,
- object to processing based on legitimate interests,
- request transfer of your data where applicable, and
- withdraw consent where processing is based on consent.
Please note that some rights are subject to legal and professional exemptions. For example, I may need to retain certain records to comply with legal obligations or to defend potential legal claims.
To make a request, please contact me at admin@claycounselling.co.uk. I will normally respond within one calendar month.
Complaints
If you are concerned about how I have handled 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 Information Commissioner’s Office (ICO):
- Website: https://ico.org.uk/make-a-complaint
- Telephone: 0303 123 1113
Changes to this notice
I may update this privacy notice from time to time to reflect changes in legal requirements or in my practice. The most recent version will always be available on my website and can be provided in paper form on request.
