Privacy & Practice Policies
(Counselling — UK GDPR, DPA 2018, DPDI Act 2026)
1. Who I Am
I am Leonie Holmes, a UK‑based counsellor, registered with the BACP and working in line with its Ethical Framework.
Data Controller: Melanie Edmunds
Email: leonieholmescounselling@outlook.com
Website: leonieholmescounselling.com
Location: Essex, UK
I am responsible for how your personal information is collected, used, and stored.
2. Information I Collect
2.1 Contact Information
Name
Email address
Phone number
Emergency contact (optional)
2.2 Administrative Information
Appointment history
Invoices and payment records
Email correspondence
2.3 Clinical Information (Special Category Dat
Risk or safeguarding concerns
Protected characteristics (e.g., ethnicity, sexuality, gender identity)
All sensitive data is handled with the highest level of confidentiality.
3. Lawful Bases for Processing
I process personal data under the following lawful bases:
Contract — to provide counselling and psychotherapy
Legitimate Interests — responding to enquiries, managing appointments, maintaining records
Legal Obligation — safeguarding, court orders, HMRC requirements
Vital Interests — serious risk of harm
Special Category Data — Article 9(2)(h) (healthcare) and Article 9(2)(a) (explicit consent where required)
4. How Your Information Is Used
Your information is used to:
Provide counselling
Maintain clinical and administrative records
Communicate about appointments
Manage payments
Meet ethical, legal, and safeguarding obligations
Discuss anonymised material in supervision
I do not use your data for marketing.
5. Storage of Notes & Data Security
Your data is stored securely using:
Encrypted devices
Password‑protected systems
Secure Outlook email
Encrypted OneDrive cloud storage
Locked physical storage (if used)
Only I have access to your identifiable information.
6. Retention Periods
Adult counselling notes: 7 years after final session
Supervision notes: 7 years
Financial records: 6 years (HMRC requirement)
Enquiry emails: 12 months
Safeguarding records: retained per statutory guidance
7. Sharing Your Information
I will only share information when:
7.1 Required by Law
Serious risk of harm
Safeguarding concerns
Court orders
7.2 With Your Explicit Consent
GP involvement
Multi‑agency work
Professional referrals
I do not sell or trade your data.
8. Your Rights
You may request to:
Access your data
Correct inaccuracies
Request deletion (where appropriate)
Restrict or object to processing
Request data portability
Withdraw consent (where consent is the basis)
9. Website Data &
Website Analytics
Your browser may automatically share:
IP address
Browser type
Basic usage data
No advertising or tracking cookies are used.
10. Data Breach Procedure
If a data breach occurs that risks your rights or freedoms, I will:
Notify you without undue delay
Notify the ICO within 72 hours (if required)
I will secure systems, assess impact, document the breach, and take steps to prevent recurrence.
11. Online Counselling & Supervision Policy
Sessions take place via WhatsApp Video using a private, password‑protected account
Sessions are not recorded
Clients must ensure privacy at their location
If connection drops, I will attempt reconnection for 10 minutes, then continue by phone or reschedule
Clients confirm their location and provide an emergency contact at each session
Online work may not be suitable for everyone; alternatives may be discussed
12. Diversity & Inclusion Statement
I welcome clients and supervisees of all identities, including diversity in:
race and ethnicity
gender identity and expression
sexual orientation
disability and neurodivergence
age
religion or belief
relationship style or family structure
socioeconomic background
My practice is guided by the BACP Ethical Framework, ongoing CPD, and a commitment to challenging discrimination and inequality.
13. Processor Agreements
Microsoft Outlook (Email)
Microsoft acts as a data processor, providing encrypted email services compliant with GDPR and the Microsoft Data Protection Addendum.
Microsoft OneDrive (Cloud Storage)
Microsoft acts as a data processor, providing encrypted cloud storage with secure access controls and multi‑factor authentication.
I remain the data controller.
14. Safeguarding Statement
I follow UK safeguarding legislation and the BACP Ethical Framework. I may share information if I become aware of:
risk of harm to you or others
child or vulnerable adult safeguarding concerns
serious crime
legal requirements
Where possible, I will discuss this with you first. I share only the minimum necessary information.
15. Complaints Procedure
If you have concerns about how your information is handled, please contact me at leonieholmescounselling@gmail.com. I aim to respond within 30 days.
If unresolved, you may contact:
Information Commissioner’s Office (ICO) — data protection concerns
British Association for Counselling and Psychotherapy (BACP) — ethical or professional concerns
You have the right to make a complaint at any time.
16. How to Raise Concerns
If you have concerns about our work together, you are welcome to raise them in session or by email. I will respond thoughtfully and within a reasonable timeframe. If you feel unable to speak with me directly, or the issue remains unresolved, you may contact the BACP or ICO.
18. Updates to This Policy
This policy reflects the DPDI Act changes effective 19 June 2026. Future updates will be posted on this website.