GDPR Policy
Last updated: 09 August 2026
My Commitment to Your Privacy
Trust is at the heart of our therapeutic relationship. When you share personal information with me, I treat it with the same care and respect I bring to our work together. Protecting your privacy isn't just a legal requirement — it's fundamental to creating a safe space where you can speak openly. This statement explains what information I collect, why I need it, and how I keep it safe.
What Information I Collect
To provide therapy and manage our working relationship, I collect and keep:
•Your name and contact details (phone number, email address, postal address)
•Emergency contact information
•Details about what brings you to therapy (your presenting issues)
•Brief, anonymised session notes recording our work together
•Relevant medical or health history you share with me
•Payment information and records
Why I Collect This Information
I have a legal basis for processing your personal data under UK data protection law. For general personal data I rely on Article 6(1)(b) UK GDPR — processing is necessary for the performance of the therapeutic contract between us. In plain terms, I need your contact details and session information to provide the therapy service you've asked for.
For health-related information: Because therapy involves sensitive health data, I rely on Article 9(2)(h) UK GDPR — processing is necessary for the provision of health or social care treatment by a health professional. The additional condition under DPA 2018 Schedule 1, Part 1, paragraph 2 (health or social care) also applies. This recognises that as a qualified therapist, I'm subject to a professional duty of confidentiality.
Professional Supervision - As part of maintaining high professional standards, I discuss my clinical work in supervision with a qualified clinical supervisor. This is essential for ensuring you receive safe, effective therapy.
Your identity is always protected. I do not share your name or any identifying details with my supervisor. All case discussion uses anonymised material only — my supervisor will never know who you are. My supervisor is bound by their own professional body's confidentiality requirements.
Clinical Will Arrangements
I have a clinical will in place to ensure your records are handled appropriately in the unlikely event I become unable to continue practising (for example, due to serious illness or death). If I am unable to practice, and only in this event, access is strictly limited to what is necessary to implement my Clinical Will and manage client contact and records appropriately by my colleagues in Arbour Counselling. My Clinical Will Executors are Laura Odom (email: Lauraodomtherapy@gmail.com) and Kate Pegg (email: hello@katepeggcounselling.co.uk). They will use these details to contact you only to inform you that I am unable to continue therapy with you. My colleagues are both members of the BACP and as such work within the BACP ethical framework, which includes confidentiality.
Who Else May See Your Information
Beyond myself, the following people or services may have limited access to your information:
•Clinical supervisor — anonymised case material only, as described above.
•Employee Assistance Programme (EAP) or referral platform — if you were referred through your employer's EAP or another referral service, I may share limited information with them as part of the commissioning arrangement (for example, confirming attendance or number of sessions).
•Website and technology providers — this website is built and hosted on Wix, which may process certain technical data. Hostinger provides domain registration services. If we have online sessions, Google Meet processes video and audio data. WhatsApp may be used for administrative communications.
•Statutory authorities — only where I am legally required to share information (see below).
When I Might Need to Break Confidentiality
What you share in therapy is confidential. However, there are rare circumstances where I may need to share information without your consent:
•If I believe there is a serious risk of harm to you or someone else
•If there are safeguarding concerns about a child or vulnerable adult
•Where disclosure is required or authorised by law, including where I am required to comply with a court order or certain legal obligations
Wherever possible, I will discuss this with you first and explain my concerns before taking any action.
How Long I Keep Your Records
I normally retain counselling records for seven years following the end of counselling. This retention period takes account of professional, legal and professional indemnity insurance considerations and the potential need to establish, exercise or defend legal claims. Other categories of information may be retained for different periods. Full details can be found in my Data Retention Policy. After this time, paper records are shredded, and electronic records are permanently deleted.
Your Rights
You have rights over your personal information. In straightforward terms, you can:
•See your records — ask me for a copy of the information I hold about you
•Correct mistakes — ask me to put right anything that's inaccurate
•Request deletion — ask me to delete your records, though I may need to keep some information for legal or insurance purposes
•Restrict processing — ask me to limit how I use your data in certain circumstances
•Object to processing — raise concerns about how I'm using your information
•Data portability — receive your data in a format you can take elsewhere.
If you'd like to exercise any of these rights, just get in touch with me directly.
Making a Complaint
If you have concerns about how I have collected, used, stored, shared or otherwise handled your personal information, please contact me in the first instance so that I have the opportunity to investigate and resolve the matter.
Email: info@albacounselling.org
I will acknowledge receipt of a data protection complaint within 30 days. I will take appropriate steps to investigate the complaint without undue delay, keep you informed where appropriate, and let you know the outcome of my investigation.
If you remain dissatisfied following my response, you have the right to raise your concern with the Information Commissioner’s Office (ICO).
Artificial Intelligence (AI)
Alba Counselling does not use artificial intelligence (AI) to record, transcribe or analyse counselling sessions.
Cinzia Procter
Alba Counselling & Psychotherapy.
Legal Entity: Alba Counselling and Psychotherapy is a trading name of Cinzia Procter Counselling and Psychotherapy Ltd; a company registered in England and Wales (Company Number 16965125). All counselling and psychotherapy services are provided by Cinzia Procter Counselling and Psychotherapy Ltd.
