Xanthe Ivory Counselling

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. My Privacy policy follows what is written and implemented by the Data Protection Act 2018. As well as the General Data Protection Regulation (EU/2016/679) (GDPR), and the Privacy and Electronic Communications (EC Directive) Regulations 2003. Other necessary considerations are made to overriding legal obligations, insurance stipulations, BACP’s Ethical Framework, client safety, and the safety of others.

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 that it is for provision of health treatment (in this case counselling) and necessary for a contract with a health professional (in this case, a contract between me and you).

The data I keep is specific to the therapy you receive. It will include your main details - name, address, email, assessment questionnaire answers, very brief session notes, and any additional therapy work such as artwork. No details are not kept in hard copy. • Session notes are often random memory joggers, thoughts, and prompts for ongoing sessions. They are never blow-by-blow accounts of our sessions together. All notes are saved on a Datashur password protected encrypted memory stick - encryption USB 2.0 IS-FLDA-256-4.

With Initial contact when you enquire about my counselling services, I will collect information to help with your enquiry. This will include your name, email address and phone number. Alternatively, your GP or other health professional may send me your details when making a referral or a parent or trusted individual may give me your details when making an inquiry on your behalf.

If you decide not to proceed, I will ensure all your personal data is deleted within 3-5 working days. If you would like me to delete this information sooner, please request it.

You legally have the right to ask for your details to be deleted, however, as a psychotherapy practice, I am bound to keep your records for 7yrs in accordance with my insurer’s requirements.

You have the right to see your data kept on file. Should you wish to see that data you can make a ‘Subject Access Request’ to me by email, and I will respond via email; when making this request please consider the security of email and your data.

  • In the event of my being notified of your death your details are destroyed. The General Medical Council for health professionals indicates confidentiality stands after your death.
  • In the event of my death all your details are destroyed after you are notified by a trusted nominated therapist. Details are deleted by destroying the memory stick unless you request they be passed on to another therapist.
  • Appointments are entered using your first name and chosen main contact details, this allows a nominated third person to contact you quickly and efficiently should I have an accident or emergency. You have the right not to have your contact details noted.
  • You have the right not to be contacted. However, if it is necessary to cancel your appointment at short notice, please be aware that you could log on to an appointment to find I’m not there.
  • Your data will not be shared with any third party, save meeting legal obligations, or by court order, or by a BACP registered therapist who takes responsibility for contacting you in the event I have an accident or emergency.
  • Should you wish me to pass on details or write a letter on your behalf for whatever reason, this request must be made in writing and signed by you. The letter should state clearly that you have thought about the implications of passing on such information on your privacy, and that you agree to it.
  • No online work is guaranteed 100% confidential, even using an encrypted platform, firewalls etc… Your privacy should always be considered before proceeding with this medium of therapy

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 www.ico.org.uk/your-data-matters.

To make a request for any personal information I may hold about you, please put the request in writing addressing it to hello@xantheivorycounselling.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 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 www.ico.org.uk/make-a-complaint 


My website uses a third-party service, which collects standard internet log information and details of visitor behaviour patterns.This is purely to see how many visitors there are to the site,this information is unidentifiable.

I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.

The website uses cookies and Google Analytics. Almost all websites use cookies which are small files that get put on your computer by websites as you surf them. These cookies can store lots of information which can have privacy implications. Google Analytics is a service provided by Google that gathers anonymous data on how people are using websites and then provides visitor statistics, details of page views etc. This service is used by many website owners as the data helps website owners to improve their websites. 

Like most websites, we use cookies to help the site work more efficiently - find out about our use of cookies https://allaboutcookies.org/ . No user-specific data is collected by me or any third party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.

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© Xanthe Ivory Counselling 2024