Legal

Privacy Policy

Last updated: March 2026. This policy explains how your personal information is collected, used, and protected.

1. Introduction

This Privacy Policy explains how your personal information is collected, used, stored, and protected when you engage with my counselling and psychotherapy services. I am committed to safeguarding your privacy and handling your data with care, transparency, and respect โ€” in line with UK data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This policy applies to all personal data collected through my website, email communication, and therapeutic work, including clients based outside the UK.

2. Who I Am

I am Gerarda Sullivan, an Integrative Counsellor and Psychotherapist providing counselling and psychotherapy services online.

  • Contact email: sullivan‑counselling@protonmail.com
  • ICO registration number: 00012552054

I am registered with the Information Commissioner's Office (ICO) as a data controller.

3. What Personal Data I Collect

I may collect and store the following:

  • Contact details (name, email address, phone number)
  • Basic personal information shared during enquiries
  • Information shared during therapy sessions
  • Session notes recorded by me
  • Appointment and payment records
  • Relevant correspondence (emails or messages)

I only collect information that is necessary for the provision of counselling and psychotherapy services.

4. Lawful Basis for Processing

Under UK GDPR, the lawful basis for processing your personal data is provision of healthcare (UK GDPR Article 9(2)(h)) and explicit consent where required. You will be informed about how your data is used, and you may withdraw consent at any time, subject to legal and professional obligations.

5. How Your Data Is Used

Your personal data is used solely for:

  • Providing counselling and psychotherapy services
  • Managing appointments and communication
  • Maintaining accurate clinical records
  • Meeting legal, ethical, and professional obligations

Your data is never sold or used for marketing purposes.

6. How Your Data Is Stored & Protected

  • Digital records are stored on encrypted, password-protected systems
  • Any paper records are kept in a locked, secure location
  • Access to your data is restricted to me only

7. Data Retention

In line with professional and insurance requirements, clinical records are retained for seven (7) years after the end of therapy. After this period, records are securely deleted or destroyed.

8. Confidentiality & Supervision

All information shared in therapy is treated as confidential. As part of good professional practice, I engage in regular clinical supervision where aspects of my work may be discussed anonymously to ensure safe, ethical, and effective practice.

9. When Information May Be Shared

Confidentiality is only broken in rare circumstances where there is a legal or ethical obligation. These include:

  • Serious risk of harm to you or others, including risk of suicide
  • Concerns about the safety of a child or vulnerable adult
  • A legal requirement to disclose (such as a court order)
  • Disclosure of serious criminal activity

Wherever possible, I will discuss this with you before taking any action.

10. Your Rights

Under UK data protection law, you have the right to:

  • Access the personal data I hold about you
  • Request corrections to inaccurate information
  • Request restriction or erasure of your data (subject to legal limits)
  • Withdraw consent where applicable
  • Raise concerns about how your data is handled

If you have concerns about data protection, you can contact the Information Commissioner's Office at www.ico.org.uk.

11. Cookies

This website uses cookies to improve your browsing experience. Cookies are small text files stored on your device. You can accept or decline cookies when you first visit the site. Declining cookies will not affect your ability to use the site.

12. Changes to This Policy

This Privacy Policy may be updated from time to time to reflect changes in legal requirements or professional practice. The most recent version will always be available on this page.

13. Contact

If you have questions about this Privacy Policy or how your data is handled, please contact me at: sullivan‑counselling@protonmail.com

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