Privacy Policy

1. Who We Are

The Growing Space is a private counselling practice operated by Wendy Holmes. For the purpose of data protection laws, I am the Data Controller.

• Email: thegrowingspacecounselling@gmail.com

• ICO Registred

2. The Types of Information We Collect

We may collect, store, and process the following categories of data:

• Personal Identifiable Information: Name, email address, telephone number, and date of birth.

• Emergency Contact Details: Next of kin and GP contact information (collected at the start of therapy).

• Special Category Data: As part of counselling, we may process highly sensitive data regarding your physical and mental health, lifestyle, history, or relationships.

Technical & Usage Data: Your IP address, browser type, and how you interact with our website (collected automatically via Wix cookies).

3. How We Collect Your Data

We collect information from you in several ways:

• When you fill out a contact or enquiry form on our Wix website.

• When you communicate with us via email, phone, or text message.

Directly from you during initial consultations, intake assessments, or ongoing therapy sessions.

4. Lawful Basis for Processing Data

Under the UK GDPR, we must have a lawful reason to hold your data. For private practice counselling, we rely on the following bases:

• Contract: We need your basic contact details to communicate with you and deliver the counselling service you request.

• Legitimate Interests: We process brief therapeutic session records to manage our practice efficiently and meet professional insurance requirements. 

Special Category Processing (Health & Social Care): We process health data under Article 9(2)(h) of the GDPR, as it is necessary for providing confidential health or social care treatment.

​5. How We Store and Protect Your Data

Your privacy is treated with the highest level of clinical confidentiality.

• Digital Records: Any digital personal data, emails, or text messages are kept securely on password-protected devices using encrypted storage or secure email servers.

• Session Notes: Brief therapeutic notes are fully anonymised using a unique client code and are stored entirely separate from your identifiable contact details. 

Website Security: Our website is hosted on Wix, which utilizes secure SSL/TLS encryption to protect information sent via web forms.

6. Information Sharing and Confidentiality

Your information will never be sold or shared for marketing purposes. Everything discussed in therapy remains confidential. We will only share your data with external parties under these strictly limited circumstances: 

• Explicit Consent: If you explicitly request or agree that we contact a third party (such as your GP or a medical professional).

• Legal Duty / Safeguarding: If we have a reasonable belief that sharing data is required by law (e.g., a court order) or is strictly necessary to prevent serious, imminent harm to yourself or another person.

• Clinical Supervision: In line with professional bodies (like the BACP/NCPS), case work is regularly reviewed with a qualified Clinical Supervisor. All cases are presented anonymously to maintain your privacy.

[Optional - Therapeutic Executor]: Professional Backup: In the unlikely event of my sudden illness or death, a trusted fellow counsellor (a Therapeutic Executor) will be granted access to client contact details solely to inform you and assist with onward care arrangements.

7. Data Retention (How Long We Keep Your Data)

We only retain your records for as long as necessary. To comply with professional insurance mandates and clinical guidelines, your anonymised session notes and contact records are kept for typically 7 years after your therapy ends. Following this timeframe, all physical data is shredded and digital files are permanently deleted.

8. Your Legal Rights

Under data protection law, you have specific rights regarding your personal information:

• The right to access: You can request a copy of the personal data we hold about you.

• The right to rectification: You can ask us to correct any inaccurate or incomplete details.

• The right to erasure ("right to be forgotten"): You can ask us to delete your personal data (though this may be limited by our legal or insurance requirements to retain records).

• The right to restrict or object to processing: You can ask us to limit how we use your data. 

To exercise any of these rights, please contact us at thegrowingspacecounselling@gmail.com

9. How to Complain

If you have any concerns about how your data is handled, please reach out to us directly so we can resolve it. You also have a legal right to lodge a complaint with the Information Commissioner’s Office (ICO) via the ICO Official Website if you feel your privacy rights have been violated.

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