Website:<\/strong> https:\/\/pruce.uk\/counselling<\/a><\/p>\n\n\n\n Data Controller:<\/strong> Nicola Pruce Counselling<\/p>\n\n\n\n ICO Registration Number:<\/strong> ZA784771<\/p>\n\n\n\n Email:<\/strong> nicola@nicolapruce.com<\/a><\/p>\n\n\n\n Last reviewed:<\/strong> 7 November 2026<\/p>\n\n\n\n Nicola Pruce Counselling is committed to protecting your privacy and maintaining the confidentiality and security of your personal information.<\/p>\n\n\n\n I am a BACP registered and accredited counsellor practising as a sole trader. I work in accordance with the British Association for Counselling and Psychotherapy (BACP) Ethical Framework for the Counselling Professions 2026, which came into effect on 3 November 2026, and applicable UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.<\/p>\n\n\n\n This Privacy Policy explains what personal information I collect, why I collect it, how it is stored and used, when it may be shared, and your rights in relation to your personal information.<\/p>\n\n\n\n It applies both to visitors to my website and to people who contact me about counselling or become clients.<\/p>\n\n\n\n I am registered with the Information Commissioner’s Office (ICO), registration number ZA784771.<\/p>\n\n\n\n My website is hosted using WordPress. When you visit the website, certain technical information may be collected automatically, including:<\/p>\n\n\n\n This information is used to maintain the security and functionality of the website and to understand how visitors use it.<\/p>\n\n\n\n This website may use cookies. Cookies are small text files stored on your device when you visit a website. They help websites function correctly and, depending on their purpose, can collect information about website usage.<\/p>\n\n\n\n Session cookies are temporary and are normally deleted when you close your browser.<\/p>\n\n\n\n Other cookies may remain on your device for a specified period.<\/p>\n\n\n\n You can manage your cookie preferences through the cookie notification displayed on the website and through your browser settings.<\/p>\n\n\n\n Non-essential cookies, including analytics or tracking cookies, will only be used where the required consent has been obtained.<\/p>\n\n\n\n I use website analytics to understand general visitor behaviour and improve the website.<\/p>\n\n\n\n Analytics may provide information such as:<\/p>\n\n\n\n I use this information for professional website analysis. I do not use it to identify individual counselling clients or for marketing purposes.<\/p>\n\n\n\n Where analytics providers process personal information on my behalf, their own privacy and data protection arrangements will also apply.<\/p>\n\n\n\n If the website allows visitors to leave comments, the information entered into the comments form may be collected, together with the visitor’s IP address and browser information. This helps with spam detection and website security.<\/p>\n\n\n\n If you choose to save your details when leaving a comment, cookies may be used to remember your name, email address and website for future comments.<\/p>\n\n\n\n If the website uses Gravatar, an anonymised string created from your email address may be provided to that service to check whether you use it.<\/p>\n\n\n\n Gravatar’s privacy policy is available at:<\/p>\n\n\n\n Any approved comment and associated profile picture may be visible publicly.<\/p>\n\n\n\n If you upload images to the website, you should avoid including embedded location information (EXIF GPS data). Visitors may be able to download images and extract this information.<\/p>\n\n\n\n Articles or pages on this website may contain embedded content from other websites, such as videos, images or articles.<\/p>\n\n\n\n Embedded content behaves in much the same way as if you had visited the other website directly. Those websites may collect information about you, use cookies or other tracking technologies, and monitor your interaction with their content.<\/p>\n\n\n\n I recommend reviewing the privacy policies of those external websites.<\/p>\n\n\n\n If you use the website’s contact button or email me directly, I will collect the information you provide, which may include your name, email address and the content of your enquiry.<\/p>\n\n\n\n I use this information solely to respond to your enquiry about the counselling services I offer.<\/p>\n\n\n\n I do not use enquiry information for marketing purposes or sell or share it with third parties for marketing.<\/p>\n\n\n\n If you decide not to proceed with counselling, your enquiry information will be deleted once the correspondence has concluded, unless there is a legitimate reason or legal requirement to retain it for longer.<\/p>\n\n\n\n If you decide to work with me, I may collect the following personal information:<\/p>\n\n\n\n Information relating to your physical or mental health is classified as special category personal data<\/strong> under UK GDPR.<\/p>\n\n\n\n I only collect information that is relevant and necessary for providing counselling safely and professionally.<\/p>\n\n\n\n Where counselling takes place online, I may also ask you to confirm your physical location at the beginning of a session. This is an important safety measure so that appropriate assistance can be sought if an emergency arises during an online session.<\/p>\n\n\n\n I use your information for the following purposes:<\/p>\n\n\n\n I do not sell your personal information or use confidential counselling information for advertising or marketing.<\/p>\n\n\n\n Under UK GDPR, I must have a lawful basis for processing personal information.<\/p>\n\n\n\n Where I process information about your health or other special category information, I must also have an additional condition under Article 9.<\/p>\n\n\n\n The lawful bases relevant to my counselling practice include the following.<\/p>\n\n\n\n Article 6 \u2013 Lawful basis for processing personal information<\/strong><\/p>\n\n\n\n Article 9 \u2013 Special category personal data<\/strong><\/p>\n\n\n\n Information about your mental and physical health is special category data.<\/p>\n\n\n\n The relevant condition for my counselling work is:<\/p>\n\n\n\n Where appropriate, I may also rely on:<\/p>\n\n\n\n These lawful bases and conditions apply according to the purpose and circumstances of the particular processing. They do not mean that all information is automatically shared or that confidentiality is routinely overridden.<\/p>\n\n\n\n Confidentiality is fundamental to my counselling practice. I respect your right to privacy and take appropriate steps to protect information you share with me.<\/p>\n\n\n\n I work in accordance with the BACP Ethical Framework for the Counselling Professions 2026, particularly its requirements concerning confidentiality, safeguarding, accountability and professional responsibility.<\/p>\n\n\n\n Information shared during counselling will normally remain confidential.<\/p>\n\n\n\n However, there are exceptional circumstances in which I may need to disclose relevant information without your consent.<\/p>\n\n\n\n These include:<\/p>\n\n\n\n Where possible and appropriate, I will discuss the situation with you before making a disclosure and explain my reasons.<\/p>\n\n\n\n However, there may be circumstances where informing you beforehand would not be appropriate or legally permitted, or could increase the risk of harm.<\/p>\n\n\n\n Any disclosure will be carefully considered, proportionate to the circumstances and limited to the information necessary for the purpose.<\/p>\n\n\n\n Where appropriate, I will consult my clinical supervisor when making decisions concerning safeguarding, confidentiality or ethical dilemmas.<\/p>\n\n\n\n I will seek to respect your wishes and privacy as far as possible, even where some disclosure is necessary.<\/p>\n\n\n\n As a BACP registered and accredited counsellor, I undertake clinical supervision as part of my professional responsibilities.<\/p>\n\n\n\n I may discuss aspects of my counselling work with my clinical supervisor to reflect on my practice, maintain professional standards and consider ethical or safeguarding issues.<\/p>\n\n\n\n Wherever possible, I use anonymised information so that you cannot be identified.<\/p>\n\n\n\n If identifiable information needs to be shared, this will only happen where there is an appropriate legal and ethical justification, consistent with my confidentiality commitments.<\/p>\n\n\n\n My supervisor is expected to maintain appropriate professional confidentiality.<\/p>\n\n\n\n I use ClinicalWill.app to maintain arrangements for the continuity of care in the event of my death or incapacity.<\/p>\n\n\n\n In these circumstances, the arrangements are intended to enable my clinical supervisor to be informed and, where necessary, to contact current clients to explain the situation and discuss appropriate arrangements for their ongoing support or alternative counselling.<\/p>\n\n\n\n Only the information necessary for this purpose will be included in the Clinical Will arrangements.<\/p>\n\n\n\n Access to this information will be restricted to the circumstances and people identified in those arrangements.<\/p>\n\n\n\n The information will be treated as confidential and handled in accordance with applicable data protection requirements.<\/p>\n\n\n\n I am a BUPA registered therapist.<\/p>\n\n\n\n If you are accessing counselling through BUPA, I may need to process and share limited personal information with BUPA for the purposes of confirming eligibility, administering your counselling sessions, submitting invoices and arranging payment.<\/p>\n\n\n\n Where applicable, this may include information necessary to process an insurance claim.<\/p>\n\n\n\n Some clients pay an excess towards their counselling fees, with BUPA paying the remaining balance.<\/p>\n\n\n\n I will only share information that is necessary for the relevant administrative or insurance purpose and will take care not to disclose unnecessary confidential counselling information.<\/p>\n\n\n\n BUPA may process your information under its own privacy policy and data protection arrangements.<\/p>\n\n\n\n I use digital systems to support the safe and effective administration of my counselling practice.<\/p>\n\n\n\n Email<\/strong><\/p>\n\n\n\n My professional email address is:<\/p>\n\n\n\n nicola@nicolapruce.com<\/a><\/p>\n\n\n\n This email service is provided through Namecheap Private Email.<\/p>\n\n\n\n Email is used for correspondence about enquiries, appointments and other necessary counselling-related administration.<\/p>\n\n\n\n Email communication carries some risk. Although email services use security measures, including encryption in transit where supported, no email system can be guaranteed to be completely secure.<\/p>\n\n\n\n Please consider carefully what personal or sensitive information you choose to send by email.<\/p>\n\n\n\n I will take reasonable precautions to protect email communications and associated personal information.<\/p>\n\n\n\n International data processing<\/strong><\/p>\n\n\n\n Namecheap’s published privacy information states that its services may involve processing and storage on servers based in the United States and other countries.<\/p>\n\n\n\n Accordingly, personal information communicated through my email service may be processed or stored outside the UK.<\/p>\n\n\n\n Any restricted international transfer of personal information must be supported by an applicable UK GDPR transfer mechanism, such as UK adequacy regulations or appropriate safeguards.<\/p>\n\n\n\n Online counselling<\/strong><\/p>\n\n\n\n Counselling sessions take place online using Microsoft Teams.<\/p>\n\n\n\n Online sessions are not recorded.<\/p>\n\n\n\n I take reasonable steps to ensure that my own environment is private and secure. I ask clients to take similar care to find a private space where they will not be overheard or interrupted.<\/p>\n\n\n\n Microsoft Teams is a third-party digital platform and its own privacy and data protection arrangements apply to its services.<\/p>\n\n\n\n Please be aware that using an online platform carries some inherent risks relating to digital security, internet connectivity and privacy.<\/p>\n\n\n\n I will not input identifiable client information into artificial intelligence tools or other external digital tools without first explaining the proposed use, its risks and obtaining your informed consent where required.<\/p>\n\n\n\n I take appropriate technical and organisational measures to protect your personal information against unauthorised access, loss, misuse, alteration or disclosure.<\/p>\n\n\n\n Depending on the type of information, records may be stored:<\/p>\n\n\n\n Access to client information is restricted to those who need it for legitimate professional purposes.<\/p>\n\n\n\n I take care to ensure that confidential information is not left accessible to unauthorised people.<\/p>\n\n\n\n I retain personal information only for as long as necessary for the purposes for which it was collected, taking account of professional, legal, insurance and financial obligations.<\/p>\n\n\n\n My retention arrangements are as follows:<\/p>\n\n\n\n Enquiries where counselling does not proceed<\/strong><\/p>\n\n\n\n If you contact me but decide not to proceed with counselling, your enquiry information will be deleted when the correspondence has concluded, unless there is a legitimate reason to retain it.<\/p>\n\n\n\n Assessment where counselling does not continue<\/strong><\/p>\n\n\n\n If you decide not to continue following an assessment session, your information will normally be securely destroyed within two weeks.<\/p>\n\n\n\n Counselling clients<\/strong><\/p>\n\n\n\n For clients who proceed with counselling, I retain relevant client records, including appropriate session notes and associated professional communications, for five years following the last counselling session<\/strong>.<\/p>\n\n\n\n Records are kept securely and are securely destroyed when the retention period ends, unless there is a lawful reason to retain particular information for longer.<\/p>\n\n\n\n Financial records<\/strong><\/p>\n\n\n\n Financial records are retained for the applicable statutory tax and accounting retention periods. These records may need to be retained separately from clinical counselling records.<\/p>\n\n\n\n Clinical Will<\/strong><\/p>\n\n\n\n Clinical Will information is maintained for as long as necessary to support the continuity-of-care arrangements and is reviewed when circumstances change.<\/p>\n\n\n\n I do not routinely share your personal information with third parties.<\/p>\n\n\n\n Information may be shared where necessary and justified for the following purposes:<\/p>\n\n\n\n Where information is shared, I will take care to ensure that the disclosure is lawful, proportionate and limited to what is necessary.<\/p>\n\n\n\n Under UK GDPR, you have a number of rights in relation to your personal information.<\/p>\n\n\n\n These include:<\/p>\n\n\n\n Right to be informed<\/strong><\/p>\n\n\n\n You have the right to know how your personal information is collected and used. This is the purpose of this Privacy Policy.<\/p>\n\n\n\n Right of access<\/strong><\/p>\n\n\n\n You can request a copy of the personal information I hold about you.<\/p>\n\n\n\n Right to rectification<\/strong><\/p>\n\n\n\n You can ask me to correct inaccurate or incomplete personal information.<\/p>\n\n\n\n Right to erasure<\/strong><\/p>\n\n\n\n You can ask for your personal information to be deleted in certain circumstances. However, this right is not absolute, and I may need to retain information where there is a lawful reason to do so.<\/p>\n\n\n\n Right to restrict processing<\/strong><\/p>\n\n\n\n You can request that I restrict the processing of your personal information in certain circumstances.<\/p>\n\n\n\n Right to data portability<\/strong><\/p>\n\n\n\n You may have the right to receive certain personal information in a commonly used electronic format, where the legal requirements are met.<\/p>\n\n\n\n Right to object<\/strong><\/p>\n\n\n\n You may object to certain types of processing, particularly where I rely on legitimate interests. This right is not absolute.<\/p>\n\n\n\n Rights relating to automated decision-making<\/strong><\/p>\n\n\n\n You have rights in relation to certain decisions made solely by automated means where those decisions have legal or similarly significant effects on you.<\/p>\n\n\n\n I do not use solely automated decision-making to make significant decisions about counselling clients.<\/p>\n\n\n\n These rights are subject to certain legal exemptions and limitations, particularly where confidentiality, legal obligations or the rights of others are involved.<\/p>\n\n\n\n Further information is available from the Information Commissioner’s Office:<\/p>\n\n\n\n https:\/\/ico.org.uk\/for-the-public<\/a><\/p>\n\n\n\n If you have any concerns about how I collect, use or store your personal information, I would encourage you to discuss them with me in the first instance, if you feel able to do so.<\/p>\n\n\n\n You also have the right to make a complaint to the Information Commissioner’s Office (ICO).<\/p>\n\n\n\n Information about making a complaint is available at:<\/p>\n\n\n\n https:\/\/ico.org.uk\/make-a-complaint<\/a><\/p>\n\n\n\n Telephone: 0303 123 1113<\/p>\n\n\n\n This Privacy Policy is reviewed regularly and may be updated to reflect changes in legislation, professional guidance, technology or the way I operate my counselling practice.<\/p>\n\n\n\n The current version will be available on my website:<\/p>\n\n\n\n https:\/\/pruce.uk\/counselling<\/a><\/p>\n\n\n\n Nicola Pruce Counselling<\/strong><\/p>\n\n\n\n Email: nicola@nicolapruce.com<\/a><\/p>\n\n\n\n ICO Registration Number: ZA784771<\/p>\n","protected":false},"excerpt":{"rendered":" Nicola Pruce Counselling Privacy Policy and Data Protection Statement Website: https:\/\/pruce.uk\/counselling Data Controller: Nicola Pruce Counselling ICO Registration Number: ZA784771 Email: nicola@nicolapruce.com Last reviewed: 7 November 2026 1. Introduction Nicola Pruce Counselling is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. I am a BACP registered and accredited … Continue reading “Privacy Policy \/ GDPR Privacy Statement”<\/span><\/a><\/p>\n","protected":false},"author":2,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"open","template":"","meta":{"footnotes":""},"class_list":["post-11","page","type-page","status-publish","hentry"],"_links":{"self":[{"href":"https:\/\/nicolapruce.com\/index.php?rest_route=\/wp\/v2\/pages\/11","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/nicolapruce.com\/index.php?rest_route=\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/nicolapruce.com\/index.php?rest_route=\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/nicolapruce.com\/index.php?rest_route=\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/nicolapruce.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=11"}],"version-history":[{"count":3,"href":"https:\/\/nicolapruce.com\/index.php?rest_route=\/wp\/v2\/pages\/11\/revisions"}],"predecessor-version":[{"id":320,"href":"https:\/\/nicolapruce.com\/index.php?rest_route=\/wp\/v2\/pages\/11\/revisions\/320"}],"wp:attachment":[{"href":"https:\/\/nicolapruce.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=11"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}1. Introduction<\/h3>\n\n\n\n
2. Information collected through my website<\/h3>\n\n\n\n
\n
Cookies<\/h4>\n\n\n\n
Website analytics<\/h4>\n\n\n\n
\n
Comments<\/h4>\n\n\n\n
Media<\/h4>\n\n\n\n
Embedded content<\/h4>\n\n\n\n
3. Contacting me through the website<\/h3>\n\n\n\n
4. Information collected when you become a counselling client<\/h3>\n\n\n\n
\n
5. How I use your personal information<\/h3>\n\n\n\n
\n
6. Lawful basis for processing your information: UK GDPR Articles 6 and 9<\/h3>\n\n\n\n
\n
\n
\n
7. Confidentiality and the limits of confidentiality<\/h3>\n\n\n\n
\n
8. Clinical supervision<\/h3>\n\n\n\n
9. Clinical Will<\/h3>\n\n\n\n
10. BUPA clients and insurance arrangements<\/h3>\n\n\n\n
11. Digital systems, email and online counselling<\/h3>\n\n\n\n
12. How your information is stored and protected<\/h3>\n\n\n\n
\n
13. How long I retain your information<\/h3>\n\n\n\n
14. Sharing your personal information<\/h3>\n\n\n\n
\n
15. Your rights under data protection law<\/h3>\n\n\n\n
16. Complaints and concerns<\/h3>\n\n\n\n
17. Changes to this Privacy Policy<\/h3>\n\n\n\n