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1. 🌿 Introduction

At Time and Tide Counselling Service, your privacy is held with care, dignity, and respect. This policy outlines how your personal data is collected, stored, and used in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Holly Harding is the named counsellor and data controller, responsible for handling your information securely, ethically, and with compassion.

2. 📘 What Information Is Collected

Depending on how you engage with the service—whether through the booking form, WhatsApp, or in-session conversations—the following data may be collected:

• Personal details: Name, date of birth, contact information

• Health-related data: Session notes, presenting concerns, referrals

• Payment details: For processing online or in-person payments

• Communication records: Emails, WhatsApp messages, appointment reminders

This may include special category data (e.g. mental health, sexuality, ethnicity), which is treated with heightened confidentiality and sensitivity.

3. ⚖️ Lawful Basis for Processing

Your data is processed under the following lawful bases:

• Contract: To provide counselling services

• Legal obligation: For record-keeping and safeguarding

• Legitimate interest: To manage the service and ensure continuity of care

• Special category data: Under Article 9(2)(h) for health and social care provision

4. 🧘 How Your Information Is Used

Your data is used gently and purposefully to:

• Schedule and manage appointments

• Deliver counselling services

• Send reminders or respond to queries

• Maintain accurate records for continuity, supervision, and reflective practice

Messages sent via WhatsApp (including Virtual Calming Room support) are treated with the same confidentiality as in-person sessions. You may opt out of message-based support at any time, with no impact on your care.

5. 🔐 Data Storage & Security

All data is stored securely using encrypted digital systems and password-protected devices. Paper records (if used) are kept in locked, access-controlled locations.

• Retention: Records are held for up to 7 years after your final session, unless otherwise required.

• Breach protocol: Any data breach will be reported to the ICO within 72 hours, if necessary, and you will be informed with transparency and support.

6. 🤝 Sharing of Information

Your data will never be shared without your explicit consent, except in the following circumstances:

• When required by law or safeguarding concerns

• With anonymised supervision for professional development

• If risk to yourself or others is disclosed, you will be informed and involved in any necessary third-party contact

Your autonomy and involvement are always prioritised.

7. 🕊️ Your Rights

You have the right to:

• Access your data

• Request corrections or deletions

• Restrict or object to processing

• Request data portability

• Lodge a complaint with the Information Commissioner’s Office (ICO)

To exercise your rights, please contact Holly Harding directly. Your voice matters.

8. 📬 Contact Information

Counsellor: Holly Harding Email: hmharding03@gmail.com Service: Time and Tide Counselling Service

9. 🌊 Boundaries & Therapeutic Relationship

To maintain professional boundaries, Holly will not initiate contact if you meet outside of sessions. If you choose to say hello, she will respond respectfully, in line with BACP ethical guidelines and your comfort.

10. ✅ Consent

By submitting a booking form, attending a session, or engaging via WhatsApp, you confirm that you’ve read and understood this Privacy & Data Protection Policy. You are welcome to ask questions or request clarification at any time.