Privacy Policy

Last updated: August 2026

Emma West Counselling is committed to protecting your privacy. This privacy policy explains why certain information is collected, how it is used, how it is protected and your rights in relation to your personal information.

Emma West is the data controller responsible for your personal information. This means that I am responsible for deciding how and why your personal information is collected and processed.

This policy applies to personal information collected when you enquire about or use the services of Emma West Counselling, and to information collected through my website.

What information is collected?

If you decide you would like to have counselling privately I will send you a ‘Personal Details Form’ which asks for information including your name, address, contact information, access requirements and emergency contact details [in case of emergency, see below].

If I see you through an EAP [Employee Assistance Programme] contact information [your name, email address and mobile number] will have been sent to me in a password protected document by Hammet Street Counselling.

In the first session I will ask you about your previous experience of counselling, why you would like to have counselling and what you hope to get out of it. I ask these questions to understand your circumstances and reasons for seeking counselling and to help ensure that the service I provide is appropriate to your needs.

This information is usually provided during a Zoom call. I make brief, pseudonymised notes during these calls to help me record the information relevant to providing an appropriate counselling service.

During the course of using the services of Emma West Counselling you may give me other personal information, for example:

Personal details
Information about your family, lifestyle, social and/or financial circumstances
Details about your employment and education
Information relating to your previous counselling sessions and your reasons for seeking counselling

You might also provide special category personal information, for example information about your:

Physical or mental health
Racial or ethnic origin
Religious or philosophical beliefs
Sexual orientation
Other information which is legally classed as special category personal data

You may also provide information relating to offences or alleged offences where this is relevant to your counselling.

Information collected through my website

This website is a static brochure. It has no accounts, no contact form, no marketing pixels and no Google Analytics or Google Fonts.

If you choose to email me, that is outside the website: you send a message from your own email account to mine.

To deliver the pages, the site is hosted on Cloudflare Pages. Cloudflare acts as my data processor and may process limited technical information that is generated automatically when your browser requests a page, such as:

Internet Protocol (IP) address
browser type and version
date and time of the request
the page requested and a referrer URL where your browser sends one

I use this information only to operate, secure and diagnose the website, on the basis of legitimate interests under Article 6(1)(f) of the UK GDPR. Cloudflare’s Data Processing Addendum includes the UK Addendum for transfers from the United Kingdom. Cloudflare is also certified under the EU–US Data Privacy Framework.

The website does not set cookies of its own. See the Cookie Policy for details.

Fonts, images and article PDFs are stored on this website and served from the same host. The site does not load fonts, scripts or analytics from Google or other advertising companies.

If you follow a link to another website, such as the BACP register or an article hosted elsewhere, that other site has its own privacy practices.

What do I use your information for?

I use your information to:

Contact you
Administer the counselling service and organise appointments with you
Provide you with a professional, effective counselling service
Keep appropriate counselling and administrative records
Identify and protect those at risk of harm or abuse, including yourself
Respond to requests or enquiries
Meet legal, professional and regulatory obligations, including obligations to insurers and professional bodies where applicable
Protect the security of my systems, records and communications
Deal with any complaints, legal claims or disputes where necessary

I will only use your personal information for purposes that are lawful, fair and transparent.

What is the lawful basis for using your information?

Data protection law requires me to have a lawful basis for processing your personal information. The lawful basis I rely on depends on the purpose for which the information is being used.

Where necessary to provide counselling and administer the counselling relationship, I may rely on performance of a contract under Article 6(1)(b) of the UK GDPR.

For some administrative, security and business purposes, I may rely on legitimate interests under Article 6(1)(f) of the UK GDPR. Where I rely on legitimate interests, I will ensure that those interests are balanced against your rights and freedoms.

Where I am required to process information to comply with a legal obligation, I may rely on legal obligation under Article 6(1)(c).

In circumstances where processing is necessary to protect someone’s life or prevent serious harm, I may rely on vital interests under Article 6(1)(d), where the relevant legal requirements are met.

Where I rely on your consent as the lawful basis for a particular processing activity, I will ask for your consent clearly and explain how you can withdraw it.

Special category information

Information about your physical or mental health, racial or ethnic origin, religious or philosophical beliefs and sexual orientation is classed as special category personal data and receives additional protection under the UK GDPR.

Where I process special category information, I will have both:

a lawful basis under Article 6 of the UK GDPR; and
an additional condition under Article 9 of the UK GDPR for processing special category information.

Where appropriate, this may include obtaining your explicit consent to the processing of special category information for specified purposes.

The fact that special category information is processed does not mean that all processing is based on consent. Different lawful bases may apply to different types of processing.

Protecting your information

I will do all I can to protect your personal data, although information sent via the internet or mobile networks cannot be guaranteed to be completely secure.

To maximise security I use a password-protected laptop and email, and my mobile has facial recognition and a passcode.

I take appropriate technical and organisational measures to protect your information against unauthorised access, accidental loss, destruction, alteration or disclosure.

Your identifiable personal information is kept separate from session notes where practicable. I also strive to anonymise session notes as much as possible.

My session notes and personal contact information are retained for 5 years after the end of counselling, after which they are securely deleted, unless there is a legal, professional, insurance or other legitimate reason why they need to be retained for longer.

Maintaining confidentiality is extremely important and I will not share information about you unless there is a lawful reason for doing so.

This may include the following circumstances:

When you have given consent: I will normally only share information with other people or organisations where you have requested or agreed that I should share it, and where it is lawful to do so.
Where there is a risk of serious harm: I may contact your GP or another appropriate person or organisation if I believe there is a serious risk of harm to you or someone else. In an emergency, information may be shared without your consent where this is necessary and lawful to protect someone’s vital interests or to prevent serious harm.
To comply with the law: I may be required to share information where there is a legal obligation to do so, for example where information is required by a court or where disclosure is otherwise required or authorised by law.
Other organisations providing services to me: Where necessary, personal information may be processed by organisations that provide services to me, such as website hosting (Cloudflare), secure email, IT or other business-support services. Where another organisation processes personal data on my behalf, I will take appropriate steps to ensure that your information is handled securely and in accordance with data protection law.

I will not sell your personal information.

Transfers of information outside the UK

Where personal information is transferred outside the UK, I will ensure that the transfer is made in accordance with the requirements of UK data protection law and that appropriate safeguards are in place where required.

Website hosting on Cloudflare may involve processing outside the UK. Those transfers are covered by Cloudflare’s Data Processing Addendum, including the UK Addendum and, where applicable, the Data Privacy Framework.

How long will I keep your information?

I will not keep your personal information for longer than is necessary for the purposes for which it is being processed.

My current retention period for your identifiable personal information and counselling session notes is 5 years after the end of counselling.

There may be circumstances where information needs to be retained for longer, for example where this is necessary to meet a legal, professional, insurance or auditing requirement, or to establish, exercise or defend a legal claim.

Website security logs held by Cloudflare are retained only for a short period for security and diagnostics.

I will review the information I hold and securely delete information when it is no longer necessary to retain it.

Your rights

Under UK data protection law, you have a number of rights in relation to your personal information.

Depending on the circumstances and the lawful basis on which I am processing your information, these include the right to:

Ask for a copy of the personal information I hold about you (right of access).
Ask me to correct inaccurate or incomplete information (right to rectification).
Ask me to delete your personal information in certain circumstances (right to erasure).
Ask me to restrict the processing of your information in certain circumstances (right to restriction of processing).
Object to certain processing of your personal information (right to object).
Request that certain information is provided to you in a structured, commonly used and machine-readable format (right to data portability), where this right applies.
Withdraw your consent where I am relying on consent as the lawful basis for processing. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

These rights are not absolute and may not apply in every circumstance. For example, I may need to retain information where this is required by law, professional obligations, insurance requirements or for the establishment, exercise or defence of legal claims.

Requests relating to your personal information should be made in writing to the email address below.

I will respond to requests within the time period required by applicable data protection law.

Your right to complain

If you have concerns about the way I have handled your personal information, I would encourage you to contact me first so that I can try to resolve your concern.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s independent supervisory authority for data protection: ico.org.uk

Who to contact

Emma West is the data controller for Emma West Counselling and is responsible for collecting and processing your personal information.

Processing includes the retrieval, organisation, use, protection, storage and deletion of information, and its disclosure to other agencies where this is lawful and appropriate.

If you have any questions about this privacy policy or how your personal information is handled, please contact:

Emma West Counselling, email: emma.west.counselling@gmail.com

My ICO registration details are recorded with the Information Commissioner’s Office. My registration number is ZA250217.

Automated decision-making

I do not use your personal information to make decisions about you solely by automated means, including profiling, which have legal or similarly significant effects on you.

Changes to this privacy policy

I may modify and update this privacy policy from time to time to reflect changes to my services, how I process personal information or changes in data protection law.

The latest version will be made available to clients and on my website where appropriate.