Privacy Notice

1. Who I am

Tours’ Safe Haven Counselling Service is a private counselling practice. For data protection purposes, the data controller is Tours Blackwell, trading as Tours’ Safe Haven Counselling Service.

Contact email: Tours.B@outlook.com

Telephone: 07881 221531

Website: www.tourssafehavencounselling.com

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2. Why I collect personal information

To provide a safe, professional counselling service, I need to collect and use some personal information. I only collect information that is relevant to providing counselling, responding to enquiries, arranging appointments, meeting professional and safeguarding responsibilities, and running the practice.

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3. Information I may collect

• Your name, date of birth and contact details.

• Parent or carer contact details where I am working with a child or young person.

• GP or other healthcare details where relevant to your care or safety.

• Information you provide when making an enquiry, completing a website form or booking an appointment.

• Brief counselling/session notes and information relevant to the therapeutic work.

• Information received from a GP, school, parent/carer or another professional where relevant and appropriate.

• Appointment, payment and administrative records.

• Limited technical information generated when you use my website, such as device, browser, IP address and cookie information. Please see the Cookie Policy for more detail.

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4. How I use your information

• To respond to enquiries and arrange consultations or counselling sessions.

• To provide counselling and maintain appropriate professional records.

• To communicate with you about appointments and practical arrangements.

• To support safeguarding and risk management where necessary.

• To meet legal, ethical, insurance and professional obligations.

• To establish, exercise or defend legal claims where necessary.

I do not sell your personal information and I do not use counselling information for unrelated marketing.

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5. Lawful basis for processing

Under the UK GDPR, I must have a lawful basis for processing personal information. When you contact me about counselling or are receiving counselling, I will usually process your ordinary personal data because it is necessary to take steps at your request before entering into a counselling contract, or to perform that contract.

After counselling ends, I may retain limited records where this is necessary for my legitimate interests in professional accountability, record keeping and the establishment or defence of potential legal claims.

Where processing is necessary to comply with a legal obligation or to protect someone’s vital interests, I may rely on those lawful bases instead.

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Counselling records may contain special category information, including information about physical or mental health. For this information I rely on an appropriate condition under Article 9 of the UK GDPR, normally the provision of health or social care/treatment while counselling is being provided and, where relevant, the establishment, exercise or defence of legal claims.

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6. Confidentiality and when information may be shared

Counselling is confidential. I will not normally share identifiable information about you without your knowledge and agreement. However, there are limited circumstances in which information may need to be shared.

• Clinical supervision. I discuss my work in regular supervision and will minimise or anonymise identifying information wherever practical.

• Safeguarding or serious risk. I may share information where I believe this is necessary to protect you, a child, a vulnerable adult or another person from serious harm.

• Legal requirements. I may disclose information if I am required or authorised to do so by law, for example by a court order.

• Healthcare or other professionals. Where appropriate, I may contact a GP or another professional with your consent, or where there is another lawful and ethical justification.

Where it is safe and appropriate, I will normally discuss a disclosure with you before it is made. There may be circumstances where this is not possible.

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7. Service providers and online systems

Some information is processed using trusted services that help me run the practice. These may include Wix for the website, forms and bookings; Microsoft 365/Outlook for email and administration; video-conferencing services used for online counselling; and payment providers where applicable.

These organisations act under their own data protection and security arrangements. Some providers may process information outside the UK. Where this happens, appropriate safeguards required by UK data protection law are used.

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8. How information is stored and protected

• Paper counselling records are stored securely and are not accessible to members of the public.

• Electronic information is protected using passwords, access controls and the security features of the systems I use.

• Only limited contact information is kept on my work phone, which is password protected.

• Website enquiries and booking information may be stored within my Wix account, and emails within Microsoft 365/Outlook.

I take reasonable steps to keep personal information accurate, secure and limited to what is necessary.

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9. How long I keep information

Counselling records are normally retained for three years from the date of your final session. They may be kept for longer where there is a legal, safeguarding, insurance or professional reason to do so.

If you make an enquiry but do not begin counselling, I will not keep the information for longer than is reasonably necessary to deal with the enquiry and any related administration.

I aim to remove your contact entry from my work phone within seven days of your final session, unless there is an outstanding administrative, safeguarding or legal reason to retain it.

For children and young people, retention arrangements may differ where safeguarding, legal or insurance requirements make this necessary.

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10. Children and young people

Where I work with a child or young person, I will explain privacy and confidentiality in language appropriate to their age and understanding. I may also hold parent or carer information where this is needed for contracting, communication, payment or safeguarding.

A child or young person has their own data protection rights. Requests for access to their information will be considered in line with their rights, age and understanding, the circumstances of the counselling and applicable law.

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11. Your data protection rights

Depending on the circumstances and the lawful basis being used, you may have the right to:

• be informed about how your personal information is used;

• ask for access to the personal information I hold about you;

• ask for inaccurate or incomplete information to be corrected;

• ask for personal information to be erased in certain circumstances;

• ask for processing to be restricted in certain circumstances;

• receive or transfer certain information in a portable format where the right to data portability applies;

• object to certain types of processing where the law gives you that right; and

• withdraw consent at any time where I am relying on consent for a particular use of your information.

These rights are not absolute and may not apply in every situation. If you make a rights request, I will normally respond within one calendar month.

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12. Automated decision-making

I do not use automated decision-making or profiling to make decisions about counselling clients.

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13. Concerns or complaints

If you have a question about how I use your personal information, or you would like to exercise a data protection right, please contact me using the details above.

If you are unhappy with how your information has been handled, you also have the right to complain to the Information Commissioner’s Office (ICO). Information about making a complaint is available at www.ico.org.uk.

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14. Changes to this notice

I may update this privacy notice from time to time to reflect changes in the law, professional guidance or the way I run the practice. The most recent version will be available on my website.