Introduction 

Your privacy is very important to me. I will handle your personal information lawfully, fairly and transparently and will only use it for specified and legitimate purposes connected with the provision and administration of counselling/psychotherapy/clinical supervision, the management of my professional responsibilities, or where otherwise required or permitted by law. I adhere to current data protection legislation, including the UK GDPR, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 and the Data (Use and Access) Act 2025. 

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This privacy notice tells you what I will do with your personal information from initial point of contact through to after your therapy has ended, including: 

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• Why I am able to process your information and what purpose I am processing it for 

• Whether you have to provide it to me

• How long I store it for 

• Whether there are other recipients of your personal information 

• Whether I intend to transfer it to another country, 

• Whether I do automated decision-making or profiling, and 

• Your data protection rights including how to make data protection complaints.

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I am happy to chat through any questions you might have about my data protection policy and you can contact me via phone (07498 219026) or email (counselling@joannabailey.com)

‘Data controller’ is the term used to describe the person/ organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is me. 

I am registered with the Information Commissioner’s Office [Reference number: ZA735646] 

I am the data controller responsible for the personal information I collect and process in connection with my counselling and clinical supervision practice.

If you have any questions about this Privacy Notice, or wish to exercise your data protection rights, you can contact me by telephone on 07498 219026 or by email at counselling@joannabailey.com. 

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My lawful basis for holding and using your personal information 

The 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: 

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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. 

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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. 

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Some information you may disclose to me, including information about your physical or mental health, is ‘special category personal data’ and receives additional protection under data protection law. Where I process special category personal data, I will have both an appropriate lawful basis under Article 6 of the UK GDPR and a separate applicable condition under Article 9. I will document the relevant basis and condition for the processing concerned and will only process such information where it is necessary and appropriate for the purpose.

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How I use your information 

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Initial contact. 

When you contact me with an enquiry about my counselling services I will collect information to help me satisfy your enquiry. This will include your name, phone number, email address, access requirements, purpose for counselling.  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 enquiry on your behalf. 

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If you decide not to proceed I will ensure all your personal data is deleted within 6 months.. If you would like me to delete this information sooner, just let me know. 

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While you are accessing counselling. 

I will protect the confidentiality and privacy of information you share with me. There are, however, circumstances in which confidentiality may be limited, including where disclosure is necessary to protect you or another person from serious harm, for safeguarding purposes, where required by law, or where necessary for appropriate professional supervision or other professional requirements. I will normally try to discuss any proposed disclosure with you first, unless doing so would be inappropriate or could increase risk or conflict with a legal or safeguarding requirement.

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I will keep a record of your personal details to help the counselling/clinical supervision services run smoothly. These details are kept securely in a safe, your mobile number will be stored in my telephone but will be coded. They are not shared with any third party. 

I will keep a combination of written and digitised notes of each session, written notes are kept securely in a locked filing cabinet and are coded so that you cannot be identified. I keep the code alongside your personal details in my secure safe. 

 

I may use Heidi Health (including its AI-assisted documentation tools) to assist me with clinical note-taking and the organisation of information arising from counselling/psychotherapy sessions. Heidi is a third-party technology service. Where Heidi acts as my data processor, I remain responsible for determining why and how your personal information is processed and for ensuring that its use is consistent with applicable data protection law and my professional and ethical obligations.

 

Heidi may process information from a counselling session in order to generate a transcription and/or draft clinical note for my review. AI-generated transcriptions and notes may contain errors, omissions or inaccuracies. Heidi is therefore used only as an assistive documentation tool. I will review the information generated by Heidi, exercise my own professional judgement and remain responsible for the accuracy, adequacy and appropriateness of the clinical record. No therapeutic, diagnostic, safeguarding or other significant decision concerning you will be made solely by Heidi or by an automated process. Transcripts are deleted once the clinical record has been completed.

 

I will use Heidi only for the limited purpose of assisting with clinical documentation. I will not use information processed through Heidi for research, teaching, publication, marketing, AI training or other secondary purposes unless I have a separate lawful and ethical basis for doing so and, where required, your informed consent.

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I will inform you before using Heidi during a session. You may ask questions about its use and may express concerns or object to its use. I will consider any objection carefully and, where reasonably practicable, offer an alternative method of note-taking or documentation. Your decision not to agree to the use of Heidi will not of itself affect your ability to receive counselling from me. If an alternative arrangement cannot reasonably be provided, I will discuss this with you before proceeding.

 

Use of Heidi for clinical documentation does not give permission for audio or video recording for research, teaching, training, supervision, publication, marketing, AI development or any other purpose. Any such recording or secondary use would be considered separately and would require an appropriate lawful and ethical basis and consent where required.

 

I will configure and use Heidi so that information held within the service is retained only for as long as necessary and appropriate. Where a transcript or draft note is no longer required after I have reviewed and incorporated the relevant information into the clinical record, I will delete it in accordance with my documented retention procedures and the settings available within the service. The retention period for my clinical records is separate from any shorter retention period applied to information within Heidi.

 

Before using Heidi, I will assess the risks associated with the technology, including confidentiality, security, data minimisation, retention, access and any relevant data transfers, and I will keep that assessment under review. I will also review the service provider’s data-processing arrangements, security information and relevant sub-processors as appropriate.

 

For security reasons I do not retain text messages after we have finished working together. If there is relevant information contained in a text message I will include it in my session notes. Likewise, any email correspondence will be deleted after we have finished working together if it is not important. If necessary, I will print it before deleting it and keep the email securely with your personal details in my secure safe. 

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After counselling has ended. 

Once counselling/clinical supervision has ended your clinical records will normally be kept for 3 years from the end of our contact with each other and are then securely destroyed. Information held in Heidi for temporary documentation purposes will be subject to the separate retention arrangements described above. If you want me to delete information sooner than this, please tell me; I will consider your request in accordance with applicable data protection law and my professional record-keeping obligations.

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Third party recipients of personal data 

I sometimes share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks. In such cases I carefully select the suppliers I work with and take appropriate steps to ensure that their processing is governed by suitable contractual and data protection arrangements. Where a supplier acts as my data processor, it may only process personal data in accordance with my documented instructions and the applicable contractual arrangements. Third parties may include technology providers such as Heidi Health where I use their services for clinical documentation.

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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 ico.org.uk/your-data-matters. 

If I do hold information about you I will: 

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• give you a description of it and where it came from; 

• tell you why I am holding its, tell you how long I will store your data and how I made this decision; 

• tell you who it could be disclosed to; 

• let you have a copy of the information in an intelligible form. 

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You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you. 

To make a request for any personal information I may hold about you, please put the request in writing addressing it to counselling@joannabailey.com. 

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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 to the contact details given above. I would welcome any suggestions for improving my data protection procedures. I will acknowledge receipt of any complaints made within 30 days of receiving them and without undue delay, take appropriate steps to respond to complaints, including making appropriate enquiries, keeping you informed and letting you know the outcome.

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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 ico.org.uk/make-a-complaint. 

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Data security 

I take the security of the data I hold about you very seriously and as such I take every effort to make sure it is kept secure. I use password protected devices, a locked filing cabinet and a secure safe.  

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Visitors to my website 

When someone visits my website, I use a third party service, Wix.com to collect standard internet log information and details of visitor behaviour patterns. I do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone. I do not make, and do not allow Wix.com to make, any attempt to find out the identities of those visiting my website. 

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

I use Wix.com so that I can continually improve my service to you, You can read Wix.com privacy notice here https://www.wix.com/about/privacy

Like most websites we use cookies to help the site work more efficiently - find out about the use of cookies. https://www.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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Revised September 2026