Privacy Policy

Last Updated: 15 June 2026

I am Sam Wright, a sole trader providing in-person and online counselling services. I am a registered accredited member of the British Association for Counselling and Psychotherapy (BACP) and operate in accordance with the BACP Ethical Framework. I am registered as a data controller with the Information Commissioner’s Office (ICO).

1. Contact Details & Business Address

  • Business Correspondence Address: 49 Westlands Road, Hunston, Chichester PO20 1PJ

  • Email Contact: sam@samw-counselling.co.uk

  • BACP Membership Number: 00828976

  • ICO Registration Number: ZA347741

2. Types of Data Collected

I collect and process personal data to provide safe, ethical, and professional therapy:

  • Identity & Contact Data: Your name, age, phone number, and email address.

  • Emergency Contact Data: Name and contact details of a trusted person or your GP (used only in crisis situations).

  • Digital & Technical Data: Your IP address, Zoom account names, and timestamps of our online meetings.

  • Special Category Data: Explicit clinical notes, psychological history, relevant medical details, and lifestyle context discussed during therapy sessions.

3. Legal Grounds for Processing Your Data

To process your basic contact data, I rely on Contractual Necessity to deliver counselling services to you.

Because counselling involves sensitive health data (Special Category Data), I also legally rely on Article 9(2)(h) of the UK GDPR. This allows the processing of health data for the provision of health or social care treatment, managed by a professional bound by the BACP’s strict code of professional secrecy and ethics.

4. Confidentiality, Storage, and Online Security

In line with BACP guidelines, our work is strictly confidential.

  • Session Notes: I store brief, anonymised clinical notes separate from your identifiable contact details. These are kept in a locked filing cabinet.

  • Zoom Security: Online sessions are conducted via a secure, password-protected Zoom account. I do not record any video or audio therapy sessions, and you are prohibited from recording them as well. You are responsible for ensuring you attend sessions from a private, secure space.

  • Exceptions to Confidentiality: I will keep your information completely confidential unless:

    1. I am legally compelled to do so by a court order.

    2. I believe there is an imminent risk of serious harm to yourself or others (Safeguarding).

    3. You explicitly request and consent in writing for me to share information with a third party (such as your GP).

  • Supervision: To ensure ethical practice, I regularly discuss my casework with a qualified BACP-registered supervisor. All client details are completely anonymised during this process.

5. Clinical Will (Professional Executor)

In accordance with BACP best practices, I have a Clinical Will in place. In the event of my sudden incapacity or death, a designated professional colleague (my Clinical Executor) will be granted secure access to your contact details. They will contact you to inform you of the situation and support you in finding alternative care. This person is also bound by strict professional confidentiality and will not read your clinical therapy notes.

6. Data Retention

I retain clinical notes and client records for 7 years following the date of our final counselling session. This specific timeframe is required to comply with my professional indemnity insurance policy and standard legal liabilities. After 7 years, all digital files are permanently erased, and paper records are securely shredded.

7. Your Rights & The Complaints Process

You have the right to request a copy of the personal data and clinical notes I hold about you (a Subject Access Request). You also have the right to ask for factual inaccuracies to be corrected.

If you have any concerns regarding how your data is handled, you can file a formal internal complaint:

  • How to submit: Email your complaint directly to sam@samw-counselling.co.uk.

  • Timeline: I will formally acknowledge receipt of your complaint within 30 days.

  • Investigation: I will review your concern and provide updates without undue delay.

  • Escalation: If you remain unsatisfied with my final response, you have the legal right to escalate the complaint to the Information Commissioner’s Office (ICO) at ico.org.uk.