Sparrow Counselling - Privacy Policy
At Sparrow Counselling, I am committed to protecting and respecting your privacy. This privacy notice explains how I collect, use, store, and protect your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Data Controller
Ben Sparrow is the Data Controller for Sparrow Counselling. If you have any questions about this privacy notice or how your data is handled, please contact ben@sparrowcounselling.online. Sparrow Counselling is formally registered with the Information Commissioner’s Office (ICO).
2. The Types of Data Collected
I may collect and process the following information:
Personal Identification: Name, date of birth, and gender identity.
Contact Information: Email address, telephone number, and residential address.
Emergency Contacts: Name and contact details of your GP and a designated emergency contact.
Special Category Data: Clinical intake forms, therapy session notes, and any relevant medical or psychological history you choose to disclose.
3. Lawful Basis for Processing Data
Under UK GDPR, I process your standard personal data under the lawful basis of Contract to fulfill our therapeutic agreement. Because clinical notes involve health data, I process your Special Category Data under Article 9(2)(h) of the UK GDPR, which permits the processing of data for the provision of health or social care treatment.
4. How Your Data is Used
Your information is used strictly to deliver safe, ethical, and effective integrative counselling services. This includes managing appointments, maintaining accurate clinical records in line with professional standards, and communicating with you regarding your sessions.
5. Data Storage and Security
I take data security exceptionally seriously. All electronic information, including your email correspondence and digital records, is stored using encrypted, secure platforms that comply fully with UK data protection standards. Any physical data is held in a secure, locked location.
6. Data Retention Period
In accordance with professional indemnity insurance requirements and clinical best practices, your personal data and clinical notes will be retained securely for a period of 7 years following the conclusion of your therapy. After this timeframe, all records will be permanently and securely destroyed.
7. Confidentiality and Sharing of Data
Your information is treated with the highest level of professional confidentiality. It will not be shared with third parties for marketing purposes. Data is only shared under the following limited and ethical exceptions:
Clinical Supervision: As a Registered Member of the BACP, my practice is regularly reviewed with a qualified clinical supervisor to ensure ethical standards. Client identity is always kept strictly anonymous during these consultations.
Safeguarding and Legal Mandates: Confidentiality may be broken if I have reason to believe that you or someone else is at risk of serious harm, or if I am legally compelled to do so by a court of law. Wherever possible, any disclosure will be discussed with you first.
8. Your Statutory Rights
Under data protection law, you hold distinct rights regarding your data, including the right to request a copy of the information I hold about you (Subject Access Request), the right to ask for inaccuracies to be corrected, and the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you believe your data has been mishandled.