Privacy & Data Policy

Anna Jones Dip.Couns MBACP
ICO Registration Number: ZC222680

Your privacy matters

I understand that choosing to come to counselling can involve sharing personal and sometimes very sensitive information. I take your privacy seriously and am committed to treating your information with care, respect and confidentiality.

This Privacy & Data Policy explains how I collect, use, store and protect your personal information in connection with my counselling practice and website.

I comply with applicable UK data protection legislation, including the UK GDPR and the Data Protection Act 2018.

Who I am

I am Anna Jones Dip.Couns MBACP, an independent integrative counsellor based in Salisbury, Wiltshire, providing counselling in person and online.

I am registered with the Information Commissioner's Office (ICO) as a data controller.

ICO Registration Number: ZC222680

As the data controller, I am responsible for deciding how and why your personal information is collected and used.

What information I collect

Depending on how you contact me and whether you become a counselling client, I may collect:

  • Your name and contact details, including your email address and telephone number

  • Information you provide when making an enquiry

  • Information required to arrange and provide counselling

  • Appointment and attendance information

  • Relevant assessment information

  • Professional counselling notes

  • Information relating to payments and invoices

  • Information relating to safeguarding where this is necessary

  • Information required to meet my professional, legal, insurance or regulatory responsibilities

I will only collect information that is relevant and necessary for the purpose for which it is being collected.

Sensitive and special category information

Counselling may involve information about your mental or physical health, relationships, trauma, family circumstances, experiences or other sensitive areas of your life.

Some of this information may constitute special category personal data under UK data protection law and therefore requires additional protection.

I process this information only where an appropriate lawful basis and special category condition apply.

I aim to keep the information I hold relevant, proportionate and limited to what is necessary for providing safe and effective counselling and meeting my professional responsibilities.

How I use your information

I may use your personal information to:

  • Respond to enquiries

  • Arrange an initial consultation

  • Arrange and manage counselling appointments

  • Provide counselling

  • Maintain appropriate professional records

  • Communicate with you about your sessions

  • Process payments and maintain financial records

  • Undertake professional supervision

  • Address safeguarding concerns where necessary

  • Meet legal, professional, insurance and regulatory requirements

  • Deal with complaints or concerns

I will not use your counselling information for marketing purposes.

Lawful basis for processing

I process personal information using the lawful basis that is appropriate to the particular purpose.

This may include:

  • Performance of a contract where processing is necessary to provide the counselling service you have requested

  • Legitimate interests for appropriate administration and management of my practice where applicable

  • Legal obligation where I am required to keep or disclose information by law

  • Vital interests in exceptional circumstances where processing is necessary to protect someone's life

Where I process special category information, such as information relating to health, I will also rely on an appropriate condition under UK data protection law.

Where consent is used as a lawful basis, it will be clear, specific and freely given, and you will be able to withdraw it where applicable.

Confidentiality

Confidentiality is an important part of the counselling relationship.

What you share with me will normally remain confidential and will not be disclosed to other people without your knowledge and agreement, subject to the limits explained below.

There are circumstances where confidentiality may need to be broken. These include:

  • A serious concern about your safety or the safety of another person

  • A safeguarding concern

  • Where disclosure is necessary to prevent serious harm

  • Where I am legally required to provide information

  • Where disclosure is necessary to meet certain professional or legal obligations

Where possible, I will discuss any proposed disclosure with you beforehand.

The limits of confidentiality are explained as part of my counselling agreement.

Professional supervision

I undertake regular professional supervision as part of my professional responsibilities and membership of BACP.

Supervision enables me to reflect on my practice and ensure that I am working safely, ethically and effectively.

When discussing your counselling in supervision, I use non-identifiable information wherever possible. Only your first name will be used and information will be discussed in a way that does not identify you.

My supervisor will not routinely receive your full personal or counselling information.

Emergency contact information

For the practical purpose of managing the counselling service, my supervisor may also hold your telephone number.

This is provided solely so that, if I am unexpectedly unavailable or there is an emergency situation requiring a session to be cancelled or rearranged, appropriate contact can be made with you.

Your telephone number will not be used by my supervisor for any other purpose.

Safeguarding

I have professional responsibilities in relation to safeguarding.

If information you share causes me to have a serious concern about the safety or wellbeing of you or another person, I may need to take appropriate action.

Any decision to share information will be considered carefully and proportionately, taking account of the circumstances, relevant professional guidance and legal requirements.

Where it is safe and appropriate to do so, I will discuss this with you first.

How your information is stored

I take appropriate steps to protect your personal information against loss, accidental destruction, misuse, unauthorised access or disclosure.

My counselling records are stored electronically using Microsoft 365.

I use appropriate security measures, including multi-factor authentication (MFA) where available.

I do not routinely keep paper counselling notes.

Email and communication

My practice email address is provided through GoDaddy.

Email may be used to arrange appointments and communicate about counselling.

I will keep communication to what is reasonably necessary and will avoid including unnecessary sensitive information in emails.

Please be aware that no method of electronic communication can be guaranteed to be completely secure.

Online counselling

Online counselling sessions are provided using Microsoft Teams.

I take reasonable steps to ensure that online sessions are conducted securely and privately.

Clients are asked to consider their own environment when attending online sessions and, wherever possible, to choose a private and confidential space.

Counselling sessions are not recorded.

Financial and accounting information

Where you make payments for counselling, relevant financial information may be processed through my business banking and accounting systems.

I use:

  • Mettle for business banking

  • FreeAgent for accounting and invoicing

I only process financial information that is necessary for managing payments, invoices, accounts and my legal and accounting obligations.

Financial records may need to be retained for longer periods where required by law.

Who I share information with

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

Personal information may be shared where this is necessary, lawful and proportionate, including:

  • With my professional supervisor, using non-identifiable information wherever possible

  • With my supervisor's access to your telephone number solely for emergency session cancellation/continuity

  • Where there is a safeguarding or serious risk concern

  • Where I am legally required to disclose information

  • Where necessary to meet professional, legal, insurance or regulatory obligations

  • With service providers who process information on my behalf, including website, email, online counselling, banking and accounting providers

Where third-party providers are used, I take reasonable steps to ensure that appropriate data protection and security arrangements are in place.

Your counselling records

I keep brief professional records where necessary to support safe and effective counselling practice.

These records are not intended to provide a detailed transcript of counselling sessions.

Counselling records are stored electronically using Microsoft 365 and protected by appropriate security measures.

How long I keep your information

I retain counselling records for seven years following the end of counselling.

This retention period reflects my professional, legal and insurance responsibilities.

Other information, such as financial and accounting records, may be retained for a different period where required by law.

When information is no longer required, it will be securely deleted or destroyed.

Your data protection rights

Under UK data protection law, you may have the right to:

  • Ask what personal information I hold about you

  • Request a copy of your personal information

  • Ask me to correct inaccurate or incomplete information

  • Request deletion of information in certain circumstances

  • Ask me to restrict how your information is processed in certain circumstances

  • Object to certain processing

  • Withdraw consent where processing is based on consent

These rights are subject to certain legal and professional exceptions.

For example, there may be circumstances where I am required to retain information even if you ask me to delete it.

If you would like to exercise any of your rights, please contact me.

Your information and the website

My website is hosted and operated using Squarespace.

When you visit the website, limited technical information may be collected automatically by Squarespace or other services used by the website. This may include information such as your IP address, browser type, device information and information about how the website is used.

The information collected will depend on the website's settings and services in use.

I will only use information for legitimate purposes such as operating, securing and maintaining the website and, where applicable, understanding how the website is used.

Cookies

My website may use cookies or similar technologies.

Some cookies may be necessary for the website to function, while others may be used for purposes such as analytics.

Where required, information about cookies and appropriate choices will be provided through the website's cookie settings or Cookie Policy.

Third-party services

My practice uses a number of trusted third-party services to operate securely and efficiently, including:

Squarespace – website hosting and website services

GoDaddy – domain registration and practice email services

Microsoft 365 / Microsoft Teams – secure electronic record keeping, email-related services where applicable, and online counselling

Mettle – business banking

FreeAgent – accounting and invoicing

These providers may process personal information on my behalf as part of providing their services.

I take reasonable steps to ensure that appropriate data protection and security arrangements are in place.

Data breaches

I take reasonable steps to prevent personal data breaches.

If a personal data breach occurs, I will assess the situation and take appropriate action in accordance with my legal and professional responsibilities, including notifying the ICO or affected individuals where this is required.

Complaints about your personal information

If you have any concerns about the way I have handled your personal information, I encourage you to contact me first so that I have the opportunity to address your concerns.

You also have the right to complain to the Information Commissioner's Office (ICO).

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

Further information about making a complaint can be found on the ICO website.

Contact me about your information

If you have any questions about this policy, the information I hold about you, or how your information is used, please contact:

Anna Jones Dip.Couns MBACP
Salisbury, Wiltshire
Email: info@annajonescounselling.co.uk

ICO Registration Number: ZC222680

Changes to this policy

I may update this Privacy & Data Policy from time to time to reflect changes to my practice, technology or legal requirements.

The most recent version will always be available on this website.

Last updated: August 2026