Your privacy is very important to me. I understand that, in coming to therapy, you may share personal and sensitive information about yourself and your life. I take my responsibility for looking after that information seriously.

This privacy notice explains what information I collect, why I collect it, how I use and store it, how long I keep it, and your rights in relation to your personal information.

I am happy to talk through any questions you may have about how I handle your information.

Who is responsible for your information?

I, Emily Clements, trading as Emily Clements Therapy, am the data controller for the personal information I hold about you.

This means that I am responsible for deciding how and why your personal information is collected and used within my practice, and for making sure it is handled appropriately and in accordance with applicable UK data protection law.

I work in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and other applicable data protection legislation.

Contact:
Emily Clements Therapy
Email: e.clements.therapy@gmail.com

Please use these contact details if you have any questions about this privacy notice, would like to make a Subject Access Request, or wish to exercise any of your data protection rights.

What information do I collect?

Depending on the stage of our contact and the nature of our work together, I may collect:

• your name and contact details, including your email address and telephone number;

• information you provide when you contact me or make an enquiry;

• information about what has brought you to therapy and what you are hoping to gain from it;

• relevant information about your health, wellbeing, previous therapy, medication, risk or safeguarding;

• assessment information and therapy notes;

• appointment, attendance and cancellation information; and

• correspondence relating to our work together.

Information about your physical or mental health is known as special category personal data and is given additional protection under UK data protection law.

I aim to collect and retain only information that is adequate, relevant and necessary for the purpose for which it is being used.

Health information

Some information I collect, such as information about your physical or mental health, is classed as special category personal data under UK data protection law.

I will only process this information where I have a lawful basis to do so and where an appropriate additional condition for processing special category data applies.

Initial contact and enquiries

When you contact me to enquire about therapy, I will collect the information I need to respond to your enquiry and consider whether I may be the right person to support you.

This may include your name, contact details, a brief outline of what has brought you to therapy, and other information that is relevant to understanding your needs or considering whether my service is appropriate for you.

If we arrange an initial consultation, I may ask questions to help me understand what support you are looking for, consider whether I am able to work with you, and identify any significant immediate safety or safeguarding concerns.

I aim to collect only the information that is necessary at each stage.

I may use a client or enquiry code within my records to reduce the amount of identifying information held alongside therapy notes and other sensitive information. Where possible, identifying information will be kept separately from clinical or therapeutic records.

If we decide not to work together, I will retain your enquiry information for 1 year after our last contact, after which it will be securely deleted or destroyed, unless there is a specific legal, professional, insurance or other legitimate reason why it needs to be retained for longer.

How do I use your information?

I may use your personal information to:

• respond to your enquiry;

• arrange and manage appointments;

• provide counselling or psychotherapy;

• consider whether my service is appropriate for your needs;

• maintain appropriate, accurate and proportionate records;

• communicate with you about your therapy and appointments;

• consider and respond appropriately to concerns about your safety or the safety of others;

• maintain financial and administrative records;

• meet my professional, ethical and legal responsibilities;

• deal with complaints, insurance or legal matters where necessary; and

• protect the security and integrity of my practice.

My lawful basis for using your information

Data protection law requires me to have a lawful basis for collecting and using your personal information.

Depending on the purpose for which your information is being used, I may process personal information where it is necessary:

• to take steps at your request before entering into an agreement to provide therapy;

• for the performance of our agreement and the provision of counselling or psychotherapy;

• to comply with a legal obligation;

• for my legitimate interests in running, administering and protecting my professional practice, where these interests are not overridden by your rights and freedoms; or

• in exceptional circumstances, to protect someone's vital interests, such as where there is a serious and immediate threat to life.

Where I process special category personal data, such as information about your physical or mental health, I will also ensure that an appropriate condition under Article 9 of the UK GDPR applies.

Where appropriate, this may include processing that is necessary for the provision of health or social care or treatment, subject to the applicable legal requirements and safeguards.

Your agreement to receive therapy is separate from consent as a lawful basis for processing personal information. If I specifically rely on your consent for a particular use of your information, I will make this clear to you.

Confidentiality and supervision

What you share with me in therapy will be treated as confidential.

As part of my professional practice, I attend regular clinical supervision. Supervision is an important part of working safely, ethically and effectively. I may discuss aspects of my therapeutic work with my clinical supervisor.

My clinical supervisor is within my professional circle of confidentiality and is expected to treat information appropriately and confidentially.

Where possible, I will avoid sharing information that identifies you unnecessarily. I will share only information that is relevant and appropriate for supervision.

There are some circumstances in which confidentiality may need to be limited. I will explain the foreseeable limits of confidentiality as part of our therapeutic agreement and will aim to discuss any proposed disclosure with you wherever it is safe and appropriate to do so.

When might information be shared?

I will not normally share your personal information with another person or organisation without discussing this with you first and, where appropriate, seeking your agreement.

For example, we may agree that it would be helpful for me to contact your GP, another healthcare professional or another service. This may be because additional support or a referral would be appropriate.

In exceptional circumstances, I may need to share information without your agreement where there is a legal or ethically recognised justification for doing so. This may include situations where:

• there is a serious and immediate risk of harm to you or another person;

• there is a safeguarding concern involving a child or vulnerable person;

• I am required to disclose information by law or a court order; or

• disclosure is otherwise legally authorised or required.

Where information does need to be shared, I will aim to share only what is necessary and proportionate to the circumstances.

Where appropriate, I may discuss a proposed disclosure with my clinical supervisor or seek professional or legal advice.

How is your information stored and kept secure?

I take the security of your personal information seriously.

Electronic client records are stored securely using my dedicated Google account, including Google Drive and Google Docs.

If we meet online, I may use Google Meet or Zoom. Online therapy sessions will never be audio or video recorded.

I use professional email for communication wherever possible. You may contact me through email for routine communication. Email services should not be relied upon for emergency or crisis support. If you are experiencing an emergency or crisis, please use the following options:

• Call 999 or go to your nearest A&E. 

• Call NHS 111 and select the mental health option to reach the Sussex Mental Healthline for free, 24/7 urgent advice. 

• Call Samaritans 116 123 for confidential, 24/7 emotional support if you are in distress. 

• Call Mental Health Rapid Response Service (MHRRS) 0300 304 0078 

Where paper records are necessary, they will be stored securely and will contain only the minimum information required.

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

Where I use another organisation to process personal information on my behalf, I will take appropriate steps to ensure that suitable data protection and security safeguards are in place.

The organisations and services I use may process or store information outside the UK. Where this occurs, I will ensure that appropriate safeguards are in place in accordance with applicable UK data protection law.

Information received from other organisations

Some enquiries may be received through therapist directories, such as the BACP Directory or Psychology Today.

I may also receive information from another healthcare professional, organisation or individual where you have asked them to contact me or make a referral on your behalf.

Any information I receive in this way will be handled in accordance with this privacy notice and applicable data protection law.

Payments and financial information

Payments may be made by cash or BACS.

I may keep information relating to payments and financial transactions where this is necessary for accounting, tax, insurance, legal or professional purposes.

Financial records will be retained for the period required by applicable legal and accounting requirements.

How long will I keep your information?

I will only keep your personal information for as long as it is necessary for the purpose for which it was collected.

If you contact me to enquire about therapy but we do not begin working together, I will retain your enquiry information for 1 year after our last contact, after which it will be securely deleted or destroyed, unless there is a specific legal, professional, insurance or other legitimate reason why it needs to be retained for longer.

Where therapy takes place, I currently retain clinical records for 7 years after therapy has ended, unless there is a specific legal, professional, insurance or other legitimate reason why they need to be kept for longer.

Clinical records may include assessment information, therapy notes, relevant correspondence, appointment information and other records relating to our work together.

When personal information is no longer required, it will be securely deleted or destroyed.

If you ask me to delete information about you, I will consider your request in accordance with your data protection rights. Please be aware that there may be circumstances in which I need to retain certain information for legal, professional, insurance or other legitimate reasons.

Your rights

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

Depending on the circumstances, these may include the right to:

• ask for access to the personal information I hold about you;

• ask for inaccurate or incomplete information to be corrected;

• ask for your information to be erased in certain circumstances;

• ask me to restrict how your information is used in certain circumstances;

• object to certain types of processing;

• request the transfer of your information in certain circumstances; and

• withdraw consent where I rely on consent to process your information.

Accessing your information

You have the right to ask for a copy of the personal information I hold about you. This is known as a Subject Access Request.

You can make a request verbally or in writing by contacting me using the details above.

I will normally respond without undue delay and within one month. In some circumstances, such as where a request is complex, or you have made multiple requests, the law allows additional time. If this applies, I will let you know.

There may also be limited circumstances in which information needs to be withheld or redacted, for example to protect another person's information or where a legal exemption applies.

Concerns or complaints about your information

If you have any questions or concerns about how I handle your personal information, please contact me first. I will always aim to discuss and resolve any concerns with you.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent regulator for data protection.

Contact

Emily Clements Therapy
Email: e.clements.therapy@gmail.com

Please use this email address if you would like to ask a question about this privacy notice, make a Subject Access Request or exercise any of your data protection rights.

Professional standards

I am a member of the British Association for Counselling and Psychotherapy (BACP) and work in accordance with the BACP Ethical Framework for the Counselling Professions and the professional standards that apply to my practice.

This privacy notice forms part of the information I provide about how I work, including confidentiality, record-keeping and the protection of your personal information. I will also discuss relevant aspects of confidentiality and privacy with you as part of our therapeutic agreement.

If you have any concerns or complaints about my service, please feel free to contact me by email or bring them to one of our sessions. I welcome the opportunity to discuss your concerns with you and will do my best to resolve any issues.

Contact

Emily Clements Therapy
Email: e.clements.therapy@gmail.com

Last updated: September 2026