Onward Counselling takes your privacy seriously. This notice explains what personal information is collected, why it is used, how it is handled, and the rights you have in relation to your information.
Development draft — some operational details are awaiting client confirmation. This notice must not be published until all marked placeholders have been resolved.
Ruth Barnes, trading as Onward Counselling, is the data controller for the personal information described in this notice.
This means Ruth Barnes is responsible for deciding how and why personal information is used.
Business structure: sole trader, to be confirmed before publication.
For questions about this notice or the use of your personal information, please contact:
The information collected depends on how someone interacts with Onward Counselling.
This may include:
This may include:
If someone becomes a counselling client, information may also include:
Onward Counselling may need to keep information connected with the counselling relationship. The exact nature and storage of any counselling or session records is currently being confirmed and will be described here before publication.
[Confirm whether counselling/session notes are kept, what they contain and where they are stored.]
Where relevant, this may include:
Personal information is used to:
Onward is not currently using personal information for newsletter marketing, advertising audiences, profiling, or automated sales campaigns.
Information shared in connection with counselling may reveal information about a person's physical or mental health, wellbeing or personal circumstances.
Health information is treated as special category personal data under UK data protection law and requires additional protection.
Onward Counselling will only process this type of information where there is an appropriate lawful basis and a valid condition for processing special category data.
[The specific Article 9 UK GDPR condition relied upon for counselling/health information must be confirmed before publication.]
The following lawful bases are provisional and must be reviewed against Ruth Barnes' actual working practices before publication.
Responding to general enquiries
Operating the practice and responding to people who contact Onward Counselling.
Provisional Article 6 basis: Legitimate interests
Booking and arranging a consultation
Arranging and administering a consultation requested by the individual.
Provisional Article 6 basis: Taking steps at the individual's request before entering into a contract
Providing counselling
Providing agreed counselling services and administering the counselling relationship.
Provisional Article 6 basis: Contract
Legal / financial records
Meeting applicable accounting, tax or legal requirements.
Provisional Article 6 basis: Legal obligation where applicable
Website security / administration
Maintaining a functioning and secure website and practice systems.
Provisional Article 6 basis: Legitimate interests
Analytics
Understanding how the website is used. Analytics should only operate where the visitor has given the required cookie consent.
Provisional Article 6 basis: Consent
Special category data
Special category condition: [To be confirmed before publication.]
Onward Counselling does not sell personal information to advertisers or data brokers.
Information may be shared where necessary with:
[Confirm any disclosure practices relating to supervision, safeguarding, emergency situations, insurers, GPs or professional bodies.]
HighLevel is used to provide website, CRM, contact-form, booking and electronic-signature functionality.
Information submitted through website forms, the booking calendar, or electronic documents may therefore be processed through HighLevel.
Microsoft 365 is expected to be used for business email and communications.
Microsoft 365 — expected email provider; to be confirmed before publication.
Google Analytics 4 may be used to understand website usage where the visitor has consented to analytics cookies. It does not run before consent has been given.
Some technology providers used by Onward Counselling may process personal information outside the United Kingdom.
Where personal information is transferred internationally and UK data protection law requires additional safeguards, appropriate transfer mechanisms will be used. These may include UK adequacy regulations, approved contractual safeguards or the UK International Data Transfer Addendum, depending on the provider and destination.
HighLevel is a US-based provider and its data-processing terms include mechanisms intended to protect restricted international transfers.
Personal information is kept only for as long as it is reasonably needed for the purpose for which it was collected, together with any applicable legal, professional or insurance requirements.
These periods will be confirmed before publication once Ruth Barnes' record-retention practices and any relevant professional requirements have been established.
Reasonable technical and organisational measures are used to protect personal information from unauthorised access, loss, misuse or disclosure.
Access to client information is limited to those who need it for a legitimate purpose, and service providers are selected with data protection and security requirements in mind.
Depending on the circumstances, you may have rights including:
Not every right applies in every situation.
To exercise a data-protection right, contact: [Privacy email to be confirmed]
The website uses cookies and similar technologies for essential functionality and, where consent is given, analytics.
Google Analytics 4 is intended to be used to understand how people use the website. Non-essential analytics should not be activated unless the visitor has given the required consent.
You can change your choices at any time through Cookie Settings.
See the Cookie Policy and Cookie Settings in the website footer below.
Onward Counselling does not currently use personal information to make solely automated decisions that have legal or similarly significant effects on individuals.
If you have a concern about how your personal information has been handled, please contact Onward Counselling first so the issue can be considered.
You also have the right to raise a complaint with the Information Commissioner's Office (ICO), the UK regulator for data protection.
This Privacy Notice may be updated from time to time to reflect changes in the way Onward Counselling works, the services used, or applicable data-protection requirements.
The latest version will always be available on this page.
For questions about this Privacy Notice or the use of your personal information, contact:
Ruth Barnes
trading as Onward Counselling