Table of Contents
- Definitions
- Our Legal Basis for Processing Your Data
- Your Rights Under Data Protection Law
- What Information We Collect
- How We Use Your Data
- Sharing Your Information
- Storing and Securing Your Data
- Remote Sessions and Confidentiality
- Cookies and Website Analytics
- Changes to This Policy
- Contact Information
- Data Protection Complaints
1. Definitions
Personal Data – Information that relates to an identifiable individual.
Processing – Any action performed on personal data, whether automated or not.
Data Subject – The person whose data is being collected or processed.
Child – Anyone under the age of 18.
Special Category Data – Sensitive personal data including information relating to physical or mental health, ethnicity, sexual orientation, religious beliefs, and other protected categories.
2. Our Legal Basis for Processing Your Data
Alice Gough Therapy collects and processes personal data under the following lawful bases:
- Consent – Where you have given clear consent for your personal data to be processed.
- Contract – Processing is necessary to provide counselling services and fulfil our agreement with you.
- Legal Obligation – Where we are required to process or disclose information to comply with legal obligations, including safeguarding responsibilities or court orders.
- Legitimate Interests – To operate and manage the practice effectively, maintain secure records, respond to enquiries, and improve our services, provided these interests do not override your rights and freedoms.
3. Your Rights Under UK GDPR
You have the right to:
- Access the personal information we hold about you.
- Request correction of inaccurate or incomplete information.
- Request the deletion of your personal information where legally appropriate.
- Restrict or object to how your information is processed.
- Request a copy of your data in a portable format where applicable.
- Withdraw your consent at any time where consent is the lawful basis for processing.
- Lodge a complaint with the Information Commissioner’s Office (ICO).
4. What Information We Collect
Depending on the services you receive, we may collect:
- Your name and contact details.
- GP and emergency contact details
- Emergency contact information.
- Relevant medical or medication information
- Availability and appointment information.
- Relevant health, wellbeing and lifestyle information.
- Counselling assessment information.
- Brief notes made during counselling sessions.
- Minimal admin messages (texts/emails for scheduling only)
- Website usage information collected through cookies and analytics.
For clients under the age of 18, records are retained for seven years after their 18th birthday, in accordance with professional insurance requirements and current guidance.
5. How We Use Your Data
Your personal information is used to:
- Provide safe and effective counselling.
- Arrange and manage appointments.
- Communicate with you regarding sessions or changes.
- Maintain secure client records.
- Meet legal, ethical and professional obligations, including safeguarding where appropriate.
- Improve the performance and functionality of our website through anonymised analytics.
Your personal information is never used for automated decision-making, and you will not receive marketing communications unless you have specifically consented to them.
6. Sharing Your Information
Your information will remain confidential and will only be shared where:
- You have provided explicit consent.
- There is a legal or safeguarding obligation to disclose information.
- Disclosure is required by a court or other lawful authority.
- Information is discussed anonymously during professional clinical supervision.
Any third-party providers used to support the practice (such as secure email, cloud storage or practice management systems) are selected with appropriate UK GDPR compliance in mind.
7. Storing and Securing Your Data
Your records are stored securely using encrypted digital systems and/or locked physical storage where appropriate.
Records are retained:
- Adults: Seven years following the end of counselling.
- Children and Young People: Seven years after their 18th birthday.
Following the appropriate retention period, records are securely and permanently destroyed.
Reasonable technical and organisational measures are in place to help protect your information against unauthorised access, disclosure, loss or misuse.
8. Remote Sessions and Confidentiality
Where counselling is provided online or by telephone:
- Sessions take place using secure online platforms.
- Clients are encouraged to choose a private, confidential location for sessions.
- Sessions are not recorded unless there is prior written agreement from both parties.
Every reasonable effort is made to maintain confidentiality during remote counselling, although no internet-based communication can ever be guaranteed to be completely secure.
9. Cookies and Website Analytics
The Alice Gough Therapy website uses cookies to improve functionality and understand how visitors use the site.
Analytics information is collected using:
- Google Analytics (anonymised website usage information).
You can manage or disable cookies through your browser settings.
To opt out of Google Analytics tracking, please visit:
The website does not use cookies for advertising or remarketing purposes.
10. Changes to This Privacy Policy
This Privacy Policy may be updated from time to time to reflect changes in legal requirements or improvements to the services provided.
Any updates will be published on this website with the revised date shown at the top of the policy.
11. Contact Information
If you have any questions about this Privacy Policy or how your personal information is processed, please contact:
Alice Gough Therapy
Email: alice@alicegoughtherapy.co.uk
Website: www.alicegoughtherapy.co.uk
For further information about data protection, please visit the Information Commissioner’s Office:
12. Data Protection Complaints
If you have concerns about how your personal information has been collected, stored, used, shared or otherwise processed by Alice Gough Therapy, you have the right to raise your concerns directly.
Complaints can be submitted by email to:
Upon receiving your complaint, we will:
- Acknowledge receipt of your complaint as soon as reasonably practicable.
- Investigate the matter fairly and without unnecessary delay.
- Keep you informed of progress where appropriate.
- Provide you with the outcome of the investigation as soon as reasonably possible.
Complaints will always be handled confidentially and in accordance with UK data protection legislation.
If you remain dissatisfied following our response, you have the right to contact the Information Commissioner’s Office (ICO).
Information Commissioner’s Office
Website: https://ico.org.uk
Telephone: 0303 123 1113 with
Suggested text: If you request a password reset, your IP address will be included in the reset email.
How long we retain your data
Suggested text: If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
Suggested text: If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where your data is sent
Suggested text: Visitor comments may be checked through an automated spam detection service.