Privacy Policy

Privacy Policy

Introduction

I am committed to protecting your privacy and handling your personal information with care, confidentiality, and in accordance with applicable data protection laws. This Privacy Policy explains how I collect, use, store, and protect your personal information when you contact me, enquire about counselling services, attend counselling
sessions, visit my website, or otherwise interact with my practice.

I process personal data in accordance with:

  • UK General Data Protection Regulation (UK GDPR)
  • Data Protection Act 2018
  • Data (Use and Access) Act 2025 (DUAA)
  • Privacy and Electronic Communications Regulations (PECR)
Data Controller

Practice Name: Spirit & Soul Counselling
Practitioner: Kirsty McCarroll
Address: Unit 5, 10 Dundas St, Grangemouth. FK38BX
Email: spiritsoulcounsellor@icloud.com
Telephone: 07988-405-420

The Information I Collect

Contact and Administrative Information

When you make an enquiry or become a client, I may collect:

  • Name
  • Date of Birth
  • Address
  • Email Address
  • Telephone Number
  • Emergency Contact Details
  • GP Details (where relevant)

Special Category Data

As a counsellor, I may collect sensitive personal information relating to:

  • Physical Health
  • Mental Health
  • Emotional Wellbeing
  • Family Circumstances
  • Personal History
  • Risk Assessments
  • Clinical Notes

This information is considered “special category data” under UK data protection law and receives additional protection

Website Information

If you visit my website, information may be collected automatically, including:

  • IP Address
  • Browser Type
  • Device Information
  • Website usage data
  • Cookies
How I Use Your Information

I use personal information to:

  • Respond to enquiries
  • Arrange and manage appointments
  • Provide counselling services
  • Maintain clinical records
  • Assess risk and ensure client safety
  • Comply with legal and professional obligations
  • Manage payments and administration
  • Improve services where appropriate
Lawful Basis for Processing

Contract
Processing is necessary to provide counselling services requested by you.

Legal Obligations
Processing may be necessary to comply with legal requirements, including safeguarding
responsibilities.

Legitimate Interests
I may process information where necessary for the effective operation of my counselling
practice, provided your rights and freedoms are protected.

Special Category Data
Health and counselling information is processed under UK GDPR provisions relating to:

  • Provision of health or social care
  • Counselling and therapeutic services
  • Establishment, exercise or defence of legal claims
  • Explicit consent where appropriate
Confidentiality

Confidentiality is a fundamental part of counselling. Information shared during counselling sessions will generally remain confidential except
where:

  • You provide consent to disclosure
  • There is a serious risk of harm to yourself or another person
  • There are safeguarding concerns involving a child or vulnerable adult
  • Disclosure is required by law or court order
  • Professional or ethical obligations require action
  • Where possible, confidentiality concerns will be discussed with you before information is
    shared.
Clinical Supervision

As part of ethical practice, I undertake regular professional supervision. Client work may be discussed anonymously with a qualified clinical supervisor. Identifying
information is removed wherever possible. The supervisor is also bound by professional confidentiality and data protection requirements.

Automated Decision-Making

I do not use automated decision-making systems that produce legal or similarly significant effects on clients. Should this change in the future, appropriate safeguards will be implemented in accordance with applicable law, including the Data (Use and Access) Act 2025.

Data Sharing

Your personal information may be shared only where necessary with:

  • Clinical supervisors (anonymised where possible)
  • Professional advisers
  • Legal representatives
  • Regulatory authorities
  • Emergency services
  • Safeguarding agencies

Information will only be shared where there is a lawful basis to do so.

I do not sell personal information to third parties.

Data Security

I take appropriate technical and organisational measures to protect your information, including:

  • Password-protected devices
  • Secure email systems
  • Encrypted storage where appropriate
  • Secure disposal of records
  • Restricted access to client information
Retention of Records

In accordance with professional guidance and insurance requirements, counselling records are typically retained for:

  • Adult clients: 3 years after the end of therapy
  • Child clients: Until the client's 25th birthday (or longer where required)
  • Records may be retained longer where necessary to meet legal, regulatory, safeguarding,
    or insurance requirements.

After the retention period expires, records will be securely destroyed.

Your Rights

Under UK data protection law, you have rights including:

  • The right to access your personal data
  • The right to request correction of inaccurate information
  • The right to request deletion in certain circumstances
  • The right to restrict processing
  • The right to object to processing
  • The right to withdraw consent where consent is relied upon
  • The right to data portability where applicable

Some rights may be limited where clinical records are involved or where legal exemptions
apply.

Data Protection Complaints

If you have concerns about how your personal information is handled, please contact me first using the details above.

I will acknowledge and investigate complaints and respond within 30 days. I will keep you informed and let you know the outcome as soon as I reasonably can and ‘without undue delay’.

If you remain dissatisfied, you have the right to complain to the Information Commissioner’s Office – https://ico.org.uk/

Website Cookies

My website may use cookies to:

  • Ensure website functionality
  • Improve user experience
  • Monitor website performance
  • Analyse website usage

Where required, consent will be obtained before non-essential cookies are used. For more information, please see the Cookie Policy.

Changes to this Privacy Policy

This Privacy Policy may be updated from time to time to reflect legal, regulatory, or operational changes. The latest version will always be available on my website.

Contact

Practice Name: Spirit & Soul Counselling
Practitioner: Kirsty McCarroll
Address: Unit 5, 10 Dundas St, Grangemouth. FK38BX
Email: spiritsoulcounsellor@icloud.com
Telephone: 07988-405-420