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Last updated: 22 July 2026

Privacy and Data Protection Policy

Introduction

I am committed to protecting your privacy and handling your personal information responsibly, securely and transparently.

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This policy explains what personal information I collect, why I use it, how it is stored, when it may be shared, how long it is retained and the rights you have in relation to your information.

Data Controller

Emma Ramarge
Private Practice Counsellor/Psychotherapist
Email: emma.ramarge.counselling@gmail.com

ICO Registration Number: 00010816372
ICO Reference: ZB744069

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I am registered with the Information Commissioner’s Office and process personal information in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018 and other applicable data-protection legislation.

Personal Information I May Collect

Depending on whether you are making an enquiry or receiving counselling, I may collect:

• Your name and contact details

• Your date of birth

• Your address, where relevant

• Emergency contact details

• Information provided in an initial enquiry

• Appointment and attendance information

• Assessment information

• Session notes and clinical records

• Information about your physical or mental health

• Information relating to risk, safeguarding or wellbeing

• Relevant information about your relationships, family circumstances or life experiences

• Correspondence between us

• Payment, invoicing and transaction information

• Information required to meet legal, insurance or professional obligations

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Counselling records are likely to contain information about physical or mental health and may include other information classed as special-category data under UK GDPR.

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I will only collect information that is relevant and reasonably necessary for providing counselling and safely and ethically managing my practice.

Children and Young People

I may provide counselling to young people aged 15–17.

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Where appropriate, I may hold limited information about a young person’s parent, carer or person with parental responsibility. This may include their name, contact details, consent information and relevant correspondence.

A young person’s counselling is treated confidentially. Information will not ordinarily be shared with a parent or carer without the young person’s knowledge and, where appropriate, their consent.

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Information may be shared where there is a safeguarding concern, a serious risk of harm, a legal requirement or another compelling reason relating to the young person’s safety or welfare. The limits of confidentiality will be discussed before counselling begins.

How I Obtain Personal Information

I usually receive personal information directly from you when you:

• Contact me by email, telephone or through my website

• Arrange an initial consultation or counselling session

• Complete an assessment, agreement or consent form

• Attend counselling sessions

• Correspond with me

• Make a payment

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In some circumstances, information may be provided by a parent, carer, healthcare professional, school, referrer or another person involved in arranging or supporting counselling.

How I Use Personal Information

I may use your information to:

• Respond to enquiries

• Assess whether I can offer an appropriate service

• Arrange and manage appointments

• Provide counselling and psychotherapy

• Maintain appropriate clinical and administrative records

• Communicate with you about your counselling

• Manage invoices and payments

• Protect the health, safety and wellbeing of clients and others

• Respond to safeguarding or serious-risk concerns

• Obtain anonymous clinical supervision

• Meet legal, ethical, insurance and professional obligations

• Manage complaints or legal claims

• Maintain the security and administration of my practice

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Your information will not be sold or used for unrelated marketing purposes.

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Lawful Bases for Processing

The lawful bases I may rely upon under Article 6 of UK GDPR include:

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Contract

Processing may be necessary to take steps at your request before counselling begins or to provide counselling under our therapeutic agreement.

Legitimate interests

Processing may be necessary for the appropriate operation of my counselling practice. This includes maintaining records, communicating with clients, managing appointments, obtaining professional supervision and protecting my legal and professional position.

Legal obligation

Processing may be necessary to comply with a legal, regulatory or professional obligation.

Vital interests

In exceptional circumstances, information may be processed or shared where necessary to protect your life or the life of another person.

Consent

Consent may be used in specific circumstances, such as when you ask me to share information with another person or professional. You may withdraw consent, although this will not affect information that was processed lawfully before consent was withdrawn.

Special-Category Information

Counselling records are likely to contain information about mental or physical health and may contain other special-category information.

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Where I process special-category information, I rely upon an appropriate condition under Article 9 of UK GDPR. Depending on the circumstances, this may include:

• The provision or management of health or social-care services

• Establishing, exercising or defending legal claims

• Protecting vital interests where a person is unable to give consent

• Explicit consent where appropriate

Providing Your Information

Some personal information is necessary for me to assess whether counselling can be offered, provide the service safely, communicate with you and meet my professional obligations.

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You are not legally required to provide all requested information. However, I may be unable to offer or continue counselling if I do not have sufficient information to provide the service safely and appropriately.

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Website and Initial Enquiries

If you contact me through my website, by email or by telephone, I will use the information you provide to respond to your enquiry and determine whether I may be able to offer an appropriate service.

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Please avoid including highly sensitive or urgent information in an initial website enquiry. My website contact form and email account are not emergency services and are not monitored continuously.

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Where counselling does not proceed, enquiry information is normally deleted within seven days from my active email and website records, unless there is a safeguarding, legal, insurance or professional reason to retain it longer. Residual copies may remain temporarily within secure backups or deleted-item retention systems.

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Confidentiality

Information disclosed during counselling is treated as confidential.

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Confidentiality is not absolute. Information may be shared without consent where:

• There is a serious or imminent risk of harm

• There is a safeguarding concern involving a child or vulnerable adult

• Disclosure is required by law or court order

• Information concerns a matter that must legally be reported

• It is necessary to protect someone’s vital interests

• Disclosure is justified by an overriding legal or ethical obligation

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Where it is safe and appropriate to do so, I will usually try to discuss a proposed disclosure with you beforehand.

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Clinical Supervision

As part of safe and ethical practice, I discuss my clinical work with a suitably qualified clinical supervisor.

Identifying details are minimised wherever possible. My supervisor is also required to maintain confidentiality and appropriate professional standards.

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Sharing Personal Information

I do not routinely share personal information with other people or organisations.

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Where necessary and legally appropriate, limited information may be shared with:

• My clinical supervisor

• Healthcare or safeguarding professionals

• Emergency services

• Legal, regulatory or professional bodies

• My professional indemnity insurer or legal adviser

• Accountancy or bookkeeping services

• Technology and administrative service providers

• A person or organisation you have authorised me to contact

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Information will only be shared where there is an appropriate lawful basis and only to the extent reasonably necessary.

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Service Providers

I use carefully selected services to operate my practice. These may include:

• Wix, which hosts and supports this website

• Email and calendar providers

• QuickBooks or other accounting and invoicing software

• Secure electronic record-storage systems

• Telephone or video-call providers

• Banking and payment-processing services

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These providers may process limited personal information on my behalf or operate as independent data controllers. They are expected to handle personal information securely and in accordance with applicable data-protection requirements.

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International Transfers

Some technology providers may process or store information outside the United Kingdom.

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Where personal information is transferred internationally, I take reasonable steps to ensure an appropriate legal safeguard is in place. This may include an adequacy decision, approved contractual clauses, the UK International Data Transfer Agreement or another safeguard recognised under UK data-protection law.

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Data Security

I take reasonable technical and organisational measures to protect personal information against unauthorised access, alteration, disclosure, loss or destruction.

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These measures may include:

• Password-protected and access-controlled systems

• Secure devices and encryption where available

• Secure electronic storage

• Locked storage for paper records

• Limiting access to information

• Separating identifying and clinical information where practicable

• Secure deletion and destruction of records

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Although no electronic communication or storage system can be guaranteed to be completely secure, I take proportionate steps to reduce foreseeable risks.

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Record Retention

Personal information is not retained indefinitely.

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Records relating to adult clients are normally retained for seven years after counselling ends.

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Records relating to clients who were under 18 when counselling took place are normally retained for seven years after the client reaches the age of 18, meaning they will ordinarily be retained until the client reaches the age of 25.

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Records may be retained for longer where required because of a safeguarding matter, complaint, legal claim, insurer requirement or another legal or professional obligation.

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When records are no longer required, they are securely deleted or destroyed.

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Your Data-Protection Rights

Depending on the circumstances and the lawful basis being used, you may have the right to:

• Be informed about how your personal information is used

• Request access to the personal information held about you

• Request correction of inaccurate or incomplete information

• Request deletion of personal information where legally appropriate

• Request restriction of processing

• Object to processing

• Request transfer of information in a portable format

• Withdraw consent where processing is based on consent

• Be informed about relevant automated decision-making

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These rights are not absolute, and legal exemptions may apply. For example, information may sometimes need to be retained to comply with a legal obligation, protect another person’s rights or establish, exercise or defend a legal claim.

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Accessing Your Records

You may make a request concerning your personal information by contacting me in writing at:

emma.ramarge.counselling@gmail.com

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I may need to verify your identity before disclosing information.

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I will respond within the timescale required by data-protection law. Information relating to another person or information covered by a lawful exemption may be withheld or redacted.

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Automated Decision-Making

I do not use personal information to make decisions about you solely through automated processing or profiling that produces legal or similarly significant effects.

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Data-Protection Complaints

Please contact me first if you have concerns about how your personal information has been handled. I will try to address the matter promptly and appropriately.

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You also have the right to complain to:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

Website Cookies

This website is hosted on the Wix platform.

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Wix may place essential cookies and similar technologies that are necessary for website security, fraud prevention, network management and basic website functionality. These cookies are required for the website to work correctly and do not require consent.

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At present, I do not knowingly use advertising or marketing cookies. This website is hosted on Wix, which may place cookies and similar technologies necessary for security and website functionality. Website applications and integrations are reviewed periodically. If non-essential cookies are used, an appropriate consent mechanism will be provided.

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A cookie consent banner is not currently displayed because this website is intended to use only cookies that are strictly necessary for its operation.

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Cookie use will be reviewed periodically. If analytics, marketing or other non-essential cookies are introduced in the future, an appropriate consent mechanism will be introduced before those cookies are placed.

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Third-party applications, embedded content or additional Wix integrations may introduce other cookies. Any new applications or integrations will therefore be reviewed before being added to the website.

Complaints Policy

My Commitment

I aim to provide a safe, respectful, ethical and professional counselling service in accordance with the BACP Ethical Framework.

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I welcome the opportunity to hear and respond to concerns. Raising a concern or complaint will not adversely affect how you are treated.

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Making a Complaint

If you are unhappy with any aspect of the service, I encourage you to discuss this with me where you feel able to do so.

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Concerns or complaints may be raised verbally or in writing.

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Written complaints can be sent to:

Emma Ramarge
Email: emma.ramarge.counselling@gmail.com

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It may be helpful to include:

• What has caused concern

• When it occurred

• Any relevant circumstances

• What outcome you are seeking

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You do not need to use a particular format.

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My Response

I will acknowledge a written complaint within seven days.

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I will consider the issues carefully, review any relevant information and aim to provide a full written response within two weeks.

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If additional time is required, I will explain the reason and provide an updated expected response date.

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Complaints will be handled respectfully, fairly and confidentially. Information will only be shared where necessary to investigate the complaint, obtain professional or legal advice or meet a legal or professional obligation.

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Possible Outcomes

Depending on the circumstances, my response may include:

• An explanation

• An acknowledgement or apology

• A discussion about whether and how the therapeutic relationship can continue

• A change to an administrative process or practice procedure

• Information about external complaints procedures

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BACP Complaints

I am a member of the British Association for Counselling and Psychotherapy.

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Where a concern cannot be resolved directly, or where you do not feel able to raise it with me, you may be entitled to submit a complaint through the BACP Professional Conduct Procedure.

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BACP determines whether a complaint is eligible under its procedure and whether it falls within the applicable time limits. Further information is available through the Professional Conduct section of the BACP website.

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Data-Protection Complaints

Concerns specifically relating to the handling of personal information may also be raised with the Information Commissioner’s Office.

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I would appreciate the opportunity to consider and respond to your concern first, but you are not prevented from approaching the ICO directly.

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Records of Complaints

Complaint correspondence and related information may be retained for as long as reasonably necessary to respond to the complaint, meet insurance and professional requirements and establish, exercise or defend legal claims.

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This policy reflects how I currently handle personal information and is reviewed regularly to ensure that it remains accurate and consistent with my practice.