Counsellor & Life Coach in Newton Abbot

Privacy and Data Protection Security Policy

This policy outlines Jo Smallbones’s procedures for collecting, storing and processing personal data in order to comply with the Data Protection Act (DPA) 2018. Personal data means data which relates to a living individual who can be identified from the data or from other information from that data.

This policy covers all principles under the DPA. These are known as the “data protection principles” and ensures information is:

  • Used fairly and lawfully
  • Used for limited, specifically stated purposes
  • Used in a way that is adequate, relevant and not excessive
  • Kept for no longer than necessary
  • Kept safe and secure
  • Not transferred outside the European Economic Area (EEA) without adequate

    Contact details for the person responsible for taking the lead on compliance;

    Jo Smallbones is registered with the Information Commissioners Office (ICO), reference ZA764998, and is therefore responsible for personal data, information on procedures dealing with both internal and external access requests and how the information collected is used.

  • What is meant by privacy:

    Privacy in its broadest sense, is about the right of an individual to be let alone. It can take two main forms, and these can be subject to different types of intrusion;

  • Physical privacy – the ability of a person to maintain their own physical space or solitude. Intrusion can come in the form of unwelcome searches of a person’s home or personal possessions, bodily searches or other interference, acts of surveillance and the taking of biometric information.

  • Information privacy – the ability of a person to control, edit, manage and delete information about themselves and to decide how and to what extent such information is communicated to others. Intrusion can come in the form of collection of excessive personal information, disclosure of personal information without consent and misuse of such information. It can include the collection of information through the surveillance or monitoring of how people act in public or private spaces and through the monitoring of communications whether by post, phone or online and extends to monitoring the records of senders and recipients as well as the content of messages.

  • Why I need the information I hold about an individual:

    I need to request and store your details in order to administer and deliver the service you have requested, and to comply with any legal or professional body responsibilities that ensue in delivering that service.

    What I am going to use it for:

    To contact you, to record the relevant personal contact details you give consent for me to hold, to record emergency contact information and where applicable to make assessments and record notes.

    Is the information being held securely:

  • I store client’s contact details and brief anonymised (no identifying details) session notes, on a secure password protected drive, that no one else has access to, on my computer. I store your contact number on a mobile phone that has face recognition and passcode security. I use only initials in my electronic bookings calendar and in my mobile contacts list and these are stored separately to any identifying documents.

  • Photos taken (with your express permission) in our session i.e to record sand tray work, along with any drawings or art works created are also stored/noted in the anonymised client notes. This will only apply to in-person counselling and not online/telephone sessions.

  • The anonymised session notes are used for my own clinical supervision. To comply with my professional body and good ethical practice I share details about my cases and client interactions, but not the client’s personal details unless a legal or safeguarding requirement requires me to.

  • How up to date the information is that I hold about you:

  • The personal information stored is as given to me on our initial contact and updated as and when you inform me of any changes.

  • Session notes will be updated usually on the day and no more than within fourteen days of delivery of such service.

  • When and how I delete the information, I hold about you:

    On your written request or at five years after our last contact, I will delete by electronic means and destroy all paper records by incineration.

    When I pass on personal information:

    I will only share personal information as follows:

  • If during my contact time with you I become aware that there is a safeguarding risk
    to either you or another person I will contact the emergency contact given and/or
    professional body/emergency services, where appropriate.

  • My supervisor will be handed all my counselling related paperwork should I become
    indisposed and will contact you and then destroy notes accordingly.

  • Where you request me to do so i.e GP reports, references etc

  • Where I need to comply with a legal requirement to do so i.e a court order.

    Please note:

    Personal information is limited only to those with a strict need to know.
    I do not use CCTV or recording equipment in any of the rooms used for counselling, nor do I record our online and telephone sessions.
    You can obtain a copy of the information I hold about you or have it removed by emailing your request to
    You have a right of access to and deletion of your records, please see the guidance on:

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