Privacy Policy
Last updated: June 2026
Privacy Policy
The Holding Place is committed to protecting your privacy and handling your personal information responsibly, securely and in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
This Privacy Policy explains what information I collect, why I collect it, how it is stored, and your rights in relation to your personal information.
Who I Am
The Holding Place is an independent counselling service providing therapeutic support online and in-person.
Email: contact.theholdingplace@gmail.com
The Holding Place is currently in the process of registering with the Information Commissioner's Office (ICO). This Privacy Policy will be updated with the ICO registration number once registration is complete.
What Information I Collect
Depending on your contact with The Holding Place, I may collect:
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Your name
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Address
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Telephone number
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Email address
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Date of birth
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Emergency contact details
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GP details
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Relevant health information
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Information shared during counselling sessions
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Risk assessments
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Session notes
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Correspondence by email or other agreed communication methods
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Payment records relating to counselling sessions
If you contact me through my website, email or social media before becoming a client, I may also retain the information you provide in order to respond to your enquiry.
Special Category Data
As a counsellor, I process special category personal data, including information relating to your physical or mental health where this is relevant to the counselling service being provided.
This information is treated with the highest level of confidentiality and security.
Why I Collect Your Information
I collect your information to:
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respond to your enquiry
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provide counselling safely and effectively
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assess risk where appropriate
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communicate with you regarding appointments
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maintain professional records
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meet legal, ethical and professional obligations
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protect you or another person where safeguarding concerns arise
I only collect information that is necessary for these purposes.
Lawful Basis for Processing
Under UK GDPR, I process personal information using one or more of the following lawful bases:
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Performance of a contract (providing counselling services)
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Legitimate interests (running my counselling practice)
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Compliance with legal obligations
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Protection of vital interests where there is serious risk of harm
Special category data relating to health is processed in accordance with Article 9 of UK GDPR where necessary for the provision of health or social care and in accordance with my professional obligations.
Confidentiality
Everything discussed during counselling is treated confidentially.
However, confidentiality may need to be broken where:
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there is a serious risk of harm to yourself
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there is a serious risk of harm to another person
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safeguarding concerns arise involving a child or vulnerable adult
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disclosure is required by law or court order
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terrorism, serious crime or money laundering legislation applies
Where appropriate and safe to do so, I will aim to discuss this with you first.
Clinical Supervision
As required by the British Association for Counselling and Psychotherapy (BACP), I attend regular clinical supervision.
Your work may be discussed anonymously with my clinical supervisor to ensure safe, ethical and effective practice.
Your name and identifying details will not normally be disclosed.
Clinical Will
In the unlikely event that I become unable to practise due to serious illness, incapacity or death, I have arrangements in place for a trusted professional colleague to access essential client contact information solely for the purpose of informing clients and supporting appropriate closure or referral.
This person will remain bound by confidentiality and UK GDPR requirements.
How Your Information Is Stored
Your information is stored securely.
Depending on the type of information, records may be held:
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electronically using password-protected systems
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within Google Workspace
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within Gmail
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securely within Zoom where required for online appointments
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on paper in locked storage
Electronic devices are password protected and appropriate security measures are used to reduce the risk of unauthorised access.
Payments
Payments are currently accepted by:
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Bank Transfer
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PayPal
Payment records are retained for accounting and legal purposes.
Bank account details are not stored beyond what is necessary to process payments.
Website
The Holding Place website is hosted by Wix.
The website may collect limited technical information, such as cookies that are necessary for the operation of the website.
If you complete a contact form, the information you provide will only be used to respond to your enquiry.
Cookies
The website uses cookies that are necessary for the functioning of the website.
Additional cookies may be used by Wix to improve website performance and user experience.
You can manage cookie preferences through your browser settings.
Third-Party Services
To provide counselling services I currently use trusted third-party providers including:
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Google Workspace
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Gmail
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Zoom
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Wix
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PayPal (where applicable)
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Microsoft Teams
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WhatsApp
These providers have their own privacy policies and security measures.
Where third-party providers process personal information on my behalf, I take reasonable steps to ensure they provide appropriate safeguards.
Who Your Information May Be Shared With
Your information will not be shared without your knowledge unless required by law or where there is a serious safeguarding concern.
Information may be shared with:
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my clinical supervisor (anonymised wherever possible)
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emergency services where there is immediate risk
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safeguarding agencies where legally or ethically required
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courts or lawful authorities where legally required
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accountants or professional advisers where necessary to meet legal obligations (financial information only)
How Long I Keep Your Information
Client records are normally retained for seven years following the end of counselling.
After this period, records are securely destroyed unless there is a legal reason requiring longer retention.
Enquiries that do not proceed to counselling are retained only for as long as reasonably necessary before being securely deleted.
Data Security
I take appropriate technical and organisational measures to protect your information from loss, misuse, unauthorised access or disclosure.
These measures include secure passwords, encrypted systems where appropriate, secure storage and regular review of data security practices.
Your Rights
Under UK GDPR you have the right to:
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request access to your personal information
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request correction of inaccurate information
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request erasure of your information where applicable
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request restriction of processing
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object to certain processing
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request transfer of your information where applicable
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withdraw consent where consent is the lawful basis for processing
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make a complaint regarding how your information is handled
Requests should be made in writing using the email address above.
Complaints
If you have concerns about how your personal information has been handled, I encourage you to contact me in the first instance so I can try to resolve the issue.
If you remain dissatisfied, you have the right to make a complaint to the Information Commissioner's Office (ICO).
Changes to this Privacy Policy
This Privacy Policy may be updated from time to time to reflect changes in legislation, professional guidance or the operation of The Holding Place.
The most recent version will always be available on the website.
Contact
If you have any questions about this Privacy Policy or how your personal information is handled, please contact:
The Holding Place