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Privacy
Policy

Trust Counselling Privacy Notice

Kieran Boddy MBACP

Effective from: 14 August 2026

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1. Who I am

 

Trust Counselling is operated by Kieran Michael John Boddy, trading as Trust Counselling. I am a registered member of the British Association for Counselling and Psychotherapy (BACP), membership number 415345.

For the purposes of UK data-protection law, I am the data controller for personal information processed by Trust Counselling.

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2. Why this notice exists

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Your privacy is important to me. This notice explains what personal information I collect, why I use it, how I protect it, when it may be shared, how long it is retained and the rights you have in relation to it. It applies to face-to-face and online counselling and to enquiries and administration connected with the service.

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3. Information I may collect

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Depending on our contact and the work we do together, I may collect and process:

  • your name and contact details, such as email address and telephone number;

  • date of birth where relevant;

  • address and, for online work where appropriate, your location at the time of a session;

  • GP and emergency-contact details;

  • information about physical or mental health, medication and other information you choose to share that is relevant to counselling;

  • brief counselling/session notes and information relevant to assessment, risk, safeguarding or our therapeutic work;

  • appointment, cancellation and correspondence records, including relevant emails and text messages;

  • payment and transaction information (I do not need to retain full bank-card details); and

  • limited technical information generated through the website or online services, where applicable.

 

4. Special-category personal information

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Counselling can involve information that UK data-protection law classifies as special-category personal data. This may include health information and, depending on what you choose to discuss, information concerning matters such as racial or ethnic origin, religious or philosophical beliefs, sexual orientation or sex life.

Special-category information receives additional legal protection. I identify an Article 6 lawful basis for processing personal information and, where special-category information is processed, an appropriate Article 9 condition and any relevant condition under the Data Protection Act 2018. Depending on the purpose and circumstances, this may include provisions relating to counselling, safeguarding, legal claims or explicit consent. I keep the legal basis for my processing under review and document it as required.

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5. How I use your information

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  • to respond to enquiries and decide whether I can offer an appropriate counselling service;

  • to provide and manage counselling sessions;

  • to communicate with you about appointments and our work together;

  • to maintain appropriate clinical and administrative records;

  • to support safe, ethical and professionally accountable practice, including clinical supervision;

  • to manage payments and business administration;

  • to meet legal, regulatory, insurance and professional obligations;

  • to respond appropriately to serious risk, safeguarding concerns or emergencies where necessary; and

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

 

6. Lawful bases

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The lawful basis used depends on why the information is being processed. In operating a private counselling practice, relevant Article 6 bases may include performance of a contract or steps taken at your request before entering into a contract; legitimate interests in operating a safe, ethical and accountable professional practice; compliance with a legal obligation where one applies; and, in exceptional circumstances, protection of vital interests.

Where I rely on legitimate interests, I consider whether my interests are necessary and proportionate and balance them against your rights and interests. Consent may be used where it is the appropriate legal basis, but counselling records are not treated as though all processing depends solely on consent.

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7. Confidentiality and clinical supervision

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What you tell me in counselling is treated as confidential. I attend regular clinical supervision as part of safe and ethical practice. Relevant aspects of client work may be discussed in supervision, but identifying information is avoided wherever practicable and only information needed for the purpose of supervision is shared.

Confidentiality is not absolute. I may need to consider disclosure where there is a serious risk of harm, a safeguarding concern, a legal obligation, a court order or another legally and ethically recognised justification. Where it is safe, lawful and appropriate, I will normally seek to discuss a proposed disclosure with you first. Any disclosure will be limited, as far as reasonably possible, to what is necessary.

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8. Online counselling and Microsoft Teams

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Online counselling is provided using Microsoft Teams. I take reasonable steps to configure and use online services in a way that supports privacy, confidentiality and data protection. You are encouraged to join sessions from a private location and to protect access to your own device and account.

Online sessions are not recorded by me as a routine part of counselling. They must not be recorded by either of us unless this has been explicitly discussed and agreed in advance. If a technical failure occurs, I may use your contact details to reconnect or agree what happens next.

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9. Digital tools and artificial intelligence

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I may use digital tools for practice administration and professional development. Before using technology in connection with client information, I consider confidentiality, privacy and data-protection risks.

I will not knowingly enter directly identifying client information into a general-purpose artificial-intelligence system for clinical analysis or decision-making without an appropriate ethical and lawful basis and, where required, your knowledge or consent. AI does not replace my professional judgement or responsibility for the counselling service.

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10. Sharing information and third-party services

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I do not sell your personal information or share it with third parties for their own marketing purposes. I may use carefully selected service providers where necessary for the operation of the practice, for example Microsoft Teams for online sessions, email or communications services, website hosting, banking/payment services or secure technology used to store or manage information.

Where another organisation processes personal information on my behalf, I take reasonable steps to consider its privacy and security arrangements and to use appropriate contractual or other safeguards where required. Information may also be disclosed where there is a lawful and ethically justified reason, as described in this notice.

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11. Storage and security

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I take reasonable technical and organisational measures to protect personal information from unauthorised access, loss, alteration or disclosure. Counselling records are stored using password-protected and/or encrypted systems or devices as appropriate. Access is limited to what is necessary for the operation of the practice and professional obligations.

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12. How long information is kept

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For adult clients, counselling records are normally retained for at least seven years after the final counselling session. This reflects the record-keeping requirements of my professional indemnity insurer, Balens, and the potential need for records in connection with complaints or legal claims.

Different or longer retention periods may apply where necessary or appropriate. Balens advises that records relating to minors should be retained for at least seven years after the person reaches 18, and that longer retention may need to be considered for vulnerable adults because limitation periods can differ. Other records, such as routine enquiries, appointment communications or financial records, may have different retention periods depending on their purpose and any legal requirements.

Information is securely deleted or destroyed when it is no longer required, subject to any continuing legal, insurance or professional reason for retaining it.

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13. Your data-protection rights

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

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

  • ask for inaccurate or incomplete information to be corrected;

  • ask for deletion of information in circumstances where the right to erasure applies;

  • ask for processing to be restricted in certain circumstances;

  • object to certain types of processing;

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

  • withdraw consent where processing is based on consent.

These rights are not absolute and may be subject to legal exemptions or competing obligations. For example, I may need to retain information despite a request for deletion where there is a lawful reason to do so. I will explain my response if you make a request that cannot be fully met.

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14. Professional incapacity or death

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I maintain professional contingency arrangements for the unexpected event that serious illness, incapacity or death prevents me from contacting current clients myself. A designated professional contact may be given access only to the minimum information necessary to notify clients and manage essential professional matters. This does not give that person general access to counselling notes.

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15. Complaints about data protection

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If you have a question or concern about how I use your personal information, please contact me first at kieran@trust-counselling.co.uk. I will take your concern seriously and try to resolve it.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data-protection regulator. Information about making a complaint is available on the ICO website at www.ico.org.uk.

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16. Changes to this Privacy Notice

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I may update this notice when my practice, professional requirements, technology or data-protection law changes. The current version will be made available through Trust Counselling. Where a change is significant and directly affects current clients, I will take reasonable steps to bring it to their attention.

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17. Contact

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For questions about this Privacy Notice or to exercise a data-protection right, contact:

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