PRIVACY NOTICE

In The Deep Therapeutic Services

Last updated: July 2026

At In The Deep Therapeutic Services, I take your privacy seriously. I understand that counselling involves sharing personal, sensitive and sometimes deeply private information, and I am committed to treating your information with care, respect and confidentiality.

This Privacy Notice explains what personal information I collect, why I collect it, how I use and protect it, how long I keep it, when it may be shared and the rights you have in relation to your personal information.

This Privacy Notice applies to clients, prospective clients and anyone who contacts In The Deep Therapeutic Services about counselling.

It has been prepared with reference to the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Data (Use and Access) Act 2025 (DUAA) and relevant guidance from the Information Commissioner’s Office (ICO).

Who is responsible for your information?

For the purposes of data-protection legislation, In The Deep Therapeutic Services is the data controller responsible for the personal information I hold and process in connection with your counselling.

In The Deep Therapeutic Services
Counsellor: Tracy Rogers
Email: inthedeeptherapy@gmail.com

If you have any questions about how your personal information is handled, or wish to exercise any of your data-protection rights, please contact me using the details above.

If you need to make a formal written request relating to your personal information, I can provide a postal address for this purpose on request.

What personal information do I collect?

The information I collect will depend on your relationship with the service and the counselling you receive.

Contact and identification information

• Your name
• Telephone number
• Email address
• Address, where necessary
• Date of birth, where relevant
• Emergency contact details, where appropriate
• Information needed to confirm your identity when necessary

Appointment and administrative information

• Appointment dates and times
• Attendance information
• Cancellation or rearrangement information
• Correspondence relating to appointments
• Information required to administer your counselling

Counselling and wellbeing information

Counselling records may contain sensitive information that you choose to share during therapy. This information is kept to a minimal amount. 

This may include information relating to:

• Your mental and emotional wellbeing
• Your physical health
• Relationships and family circumstances
• Personal history and experiences
• Trauma or distressing experiences
• Safeguarding concerns
• Other information relevant to the therapeutic work

Some of this information may constitute special category personal data, including information concerning your physical or mental health.

You are not required to share information that you do not wish to discuss during counselling.

Payment information

Where you pay for counselling, I may process information necessary to record and administer payment, including:

• Payment date
• Amount paid
• Payment method
• Payment reference or receipt number
• Information required for accounting and tax purposes

Counselling sessions are paid for by bank transfer or cash.

Where you pay by cash, the payment will be recorded using a receipt/reference number and a receipt will be provided.

Communications

I may process information contained in communications between you and In The Deep Therapeutic Services, including:

• Emails
• Text messages
• Telephone communications
• Appointment enquiries
• Other correspondence relating to your counselling

CCTV

If you attend counselling in person, external CCTV may capture your image when you enter or leave the property.

CCTV is used for security and the protection of people and property and is not used to monitor or record counselling sessions.

 

How is your information collected?

Information may be collected:

• Directly from you when you enquire about counselling
• During an initial assessment or consultation
• During counselling sessions
• Through email, text messages or telephone conversations
• Through appointment and payment administration
• From a professional or organisation involved in your care, where appropriate and lawful
• From another lawful source where necessary

Why do I use your information?

Your personal information may be used for the following purposes.

Providing counselling

To provide counselling services, understand your needs, maintain appropriate therapeutic records and support safe, ethical and effective therapeutic practice.

Managing appointments and administration

To arrange and manage appointments, communicate with you, process payments, manage cancellations and maintain appropriate business records.

Safeguarding and safety

Information may be used or disclosed where necessary to protect you or another person from serious harm, or where there is a safeguarding concern requiring action.

Where possible and appropriate, this will be discussed with you beforehand.

Professional supervision

As part of my professional practice, I receive regular clinical supervision.

Relevant information may be discussed with my clinical supervisor for professional reflection, safe practice, safeguarding and maintaining appropriate professional standards.

Information will be anonymised or appropriately de-identified wherever reasonably possible.

Legal and professional obligations

Information may be processed where necessary to:

• Comply with a legal obligation
• Comply with professional or regulatory requirements
• Respond to a lawful request from a court or other authorised body
• Establish, exercise or defend legal claims
• Protect the rights, safety or property of myself or another person

 

What is the lawful basis for using your information?

Data-protection law requires me to have a lawful basis for processing your personal information.

Depending on the circumstances, information may be processed because it is:

• Necessary for the performance of a contract with you, including providing and administering counselling services
• Necessary for compliance with a legal obligation
• Necessary for legitimate interests, where applicable and where those interests are not overridden by your rights and interests
• Processed under another lawful basis where required by law

Counselling records may contain health information and other special category personal data.

Where this is the case, an additional condition under Article 9 of the UK GDPR is required.

I will only process special category information where there is both a valid Article 6 lawful basis and an applicable Article 9 condition.

Where consent is used as a lawful basis, you will be informed of this and you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

 

Confidentiality

Confidentiality is an important part of the counselling relationship.

The information you share during counselling will normally remain confidential.

There are, however, circumstances where I may need to disclose information without your consent. This may include where:

• I believe there is a serious risk of significant harm to you or another person
• There is a safeguarding concern
• I am required to disclose information by law, including in response to a court order
• Disclosure is necessary to meet a legal, professional or safety obligation

Any decision to disclose information will be made carefully and proportionately.

Wherever possible and appropriate, I will discuss this with you beforehand.

Only information that is necessary for the relevant purpose will normally be disclosed.

Further information about the limits of confidentiality is contained within your Counselling Agreement.

Who may your information be shared with?

Your information is treated as confidential and will only be shared where there is a lawful and appropriate reason to do so.

Depending on the circumstances, this may include:

Clinical supervisor

Relevant counselling information may be discussed with my clinical supervisor as part of professional supervision.

Information will be anonymised or appropriately de-identified wherever reasonably possible.

Healthcare or other professionals

Information may be shared with your GP, healthcare professional or another professional involved in your care where you have given appropriate permission, where sharing is otherwise necessary and lawful, or where there is a safeguarding or serious safety concern requiring disclosure.

Emergency or safeguarding services

Information may be disclosed to emergency services, safeguarding services, the police or another appropriate organisation where this is necessary and lawful to protect someone from serious harm or where disclosure is required by law.

Professional, legal or regulatory advisers

Information may be shared where necessary with appropriate professional, legal, insurance or regulatory bodies, for example where required to comply with a legal or professional obligation or to establish or defend a legal claim.

Service providers

I use carefully selected third-party organisations to provide services that support the running of the counselling practice.

These currently include:

Google — Gmail and Google Meet

Google services are used for email communication and online counselling sessions.

 

Google Gmail and Google Meet

Email communication is provided using Gmail and online counselling sessions are provided using Google Meet.

Google is a third-party technology provider and may process personal information in accordance with its own privacy and security arrangements.

Information processed through these services may include your name, email address, communications and information necessary to arrange or conduct online counselling.

Google Meet is used to conduct live counselling sessions. Counselling sessions are not routinely recorded.

You should take reasonable steps to ensure that you attend online counselling from a private location and that other people cannot overhear you.

Google may process personal information outside the UK. Where this occurs, appropriate safeguards and lawful international transfer mechanisms will apply where required by UK data-protection law.

 

Email, text and telephone communications

I may use email, telephone and text messaging to communicate with you about appointments and counselling administration.

Email and text messages may contain personal information.

Please avoid including highly sensitive therapeutic information in ordinary text messages or emails unless necessary.

I will take reasonable steps to protect your information, but no electronic communication system can be guaranteed to be completely secure.

If you have a preference for how I contact you, please let me know.

 

How are counselling records stored?

Counselling records are maintained to support safe, ethical and effective professional practice.

Records may include information about:

• Presenting concerns
• Therapeutic discussions
• Relevant personal history
• Therapeutic interventions
• Risk and safeguarding considerations
• Professional reflections
• Attendance
• Information necessary to support continuity and safe practice

Electronic counselling records are created and maintained using Microsoft Word documents and stored on a password-protected USB drive.

The USB drive is kept in a locked safe when it is not in use.

Access to counselling records is restricted to the counsellor.

Appropriate physical and password security measures are used to protect your information from unauthorised access, loss, alteration or disclosure.

Paper records, where created, will also be stored securely.

 

Clinical supervision

Regular clinical supervision is an important part of safe and ethical counselling practice.

I discuss my professional work with a clinical supervisor to support:

• Safe therapeutic practice
• Professional reflection
• Ethical decision-making
• Safeguarding
• Professional development
• Maintaining appropriate standards of care

Where client information is discussed, I will anonymise or appropriately de-identify information wherever reasonably possible.

 

Payment information

Counselling sessions cost is agreed in advance and are always for one hour.

Payment is accepted by bank transfer or cash.

Bank transfer payments are recorded for accounting and business purposes.

Cash payments are recorded using a receipt book and receipt/reference number, and a receipt is provided.

Financial records are retained for the period required by applicable tax, accounting and legal requirements.

 

CCTV

External CCTV operates at the counselling premises for security purposes.

The CCTV system may record images of people entering or leaving the property.

The purposes of CCTV are to:

• Protect people and property
• Prevent and detect crime
• Support the investigation of security incidents
• Maintain the security of the premises

CCTV does not record counselling sessions.

CCTV recordings are securely stored and access is restricted.

Recordings are normally deleted within 24 hours, unless they are required for a security incident, legal obligation or other lawful purpose.

Appropriate CCTV signage is displayed at the premises.

 

How long is your information retained?

I will retain your information only for as long as it is necessary for the purpose for which it was collected, unless there is a lawful reason to retain it for longer.

Counselling records

Counselling records will normally be retained for up to seven years after the end of the therapeutic relationship.

This retention period reflects professional, legal, insurance and record-keeping considerations.

Financial records

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

CCTV

CCTV recordings are normally deleted within 24 hours, unless they are required for a security incident, legal obligation or other lawful purpose.

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

 

Your data-protection rights

Depending on the circumstances, you may have the right to:

• Be informed about how your personal information is collected and used
• Request access to the personal information held about you
• Request correction of inaccurate or incomplete information
• Request erasure of your personal information in certain circumstances
• Request restriction of processing in certain circumstances
• Object to certain processing
• Request data portability where the legal requirements for this right are met
• Have rights relating to certain automated decision-making and profiling

These rights are not absolute and exemptions or limitations may apply.

For example, information may need to be retained where there is a legal, professional, insurance or safeguarding reason to do so.

 

Subject Access Requests

You can ask for a copy of the personal information held about you. This is known as a Subject Access Request (SAR).

Requests can be made by contacting me using the following details:

Email: inthedeeptherapy@gmail.com

If a written postal request is required, I can provide a postal address for this purpose on request.

You may be asked to provide sufficient information to verify your identity before information is disclosed.

I will respond to requests within the timeframe required by applicable data-protection law.

 

Data Protection Complaints

If you have concerns about how your personal information has been collected, stored, used or otherwise processed, please contact me in the first instance.

Email: inthedeeptherapy@gmail.com

I will acknowledge and investigate data-protection complaints in accordance with applicable requirements and will provide you with the outcome of my investigation.

If you remain dissatisfied, you have the right to complain to the Information Commissioner’s Office (ICO), the UK’s independent regulator for data protection and information rights.

Further information about making a complaint to the ICO can be found on their website.

 

Data Breaches

If a personal-data breach occurs, I will assess the breach and take appropriate action in accordance with applicable data-protection law.

Where notification to the ICO or affected individuals is legally required, this will be carried out within the applicable timescales.

 

Automated Decision-Making

Your personal information will not be used to make decisions about you based solely on automated processing where that decision has legal or similarly significant effects on you.

 

Changes to this Privacy Notice

This Privacy Notice may be reviewed and updated from time to time to reflect changes in:

• Legislation
• ICO guidance
• Professional requirements
• Technology
• The services used by In The Deep Therapeutic Services
• The way personal information is processed

The current version of this Privacy Notice will be made available on the In The Deep Therapeutic Services website.

Where changes materially affect how your personal information is processed, appropriate information will be provided where required.

 

Contact

If you have any questions about this Privacy Notice or how your personal information is handled, please contact:

Tracy Rogers
In The Deep Therapeutic Services
Email: inthedeeptherapy@gmail.com

Privacy Notice version: July 2026

Frequently Asked Questions