Privacy Notice For Clients

Effective Date: 1 October 2026  |  Last Reviewed: 22 October 2026

As a Registered Member of the British Association for Counselling and Psychotherapy (MBACP), client confidentiality and personal privacy are foundational to my counselling practice. When you enter therapy, you share deeply personal experiences, feelings, and vulnerability. I treat this information with rigorous professional care, clinical integrity, and legal security.

This Privacy Notice explains how I collect, protect, hold, and process your personal and sensitive health data in accordance with the BACP Ethical Framework for the Counselling Professions, the UK General Data Protection Regulation (UK GDPR), and the Data Protection Act 2018.

1. Counsellor & Data Controller Information

I act as the Data Controller for all client records generated within my private counselling practice:

Simon Vizard
MBACP (Registered Member No. 094892), Dip. Couns. (CPCAB)
Person-Centred Counsellor in Private Practice
Practice Consulting Room:
Wallis Gardens, River Meadow, Stanford in the Vale, Oxfordshire, SN7 8FZ
Telephone: 07519 411585
Email: [email protected]
Website: www.simonvizard.co.uk

2. What Client Information I Collect

When you contract to work with me, I collect and hold the following details:

2.1 Personal & Contact Details
Your full name, preferred name and pronouns, postal address, telephone number, email address, date of birth, emergency contact name and telephone number, and your General Practitioner’s (GP) name, surgery address, and contact details.

2.2 Sensitive Health Information (Special Category Data)
Brief notes regarding your health background, relevant prescribed medications, significant family or relationship history, current psychological challenges, and brief, anonymised clinical process notes recorded following our sessions to ensure continuity of therapeutic care.

3. Why I Collect It & Lawful Basis (UK GDPR)

Under the UK GDPR and the Data Protection Act 2018, I hold your data under clear statutory lawful bases:

1. Contract (Article 6(1)(b)): Holding contact details and appointment logs is necessary to deliver the counselling service agreed in our contract.
2. Special Category Health Data (Article 9(2)(h)): Therapy records and health history constitute Special Category Data. Processing is lawful under Article 9(2)(h) for the provision of health or social care or treatment, administered by a professional bound by professional secrecy and ethics (BACP).
3. Legitimate Interests (Article 6(1)(f)): Maintaining accurate clinical records is essential to deliver safe, ethical, and accountable clinical practice.

4. How Your Records Are Stored & Protected

To provide maximum security and eliminate unauthorized access, I operate a strict principle of data minimisation and physical separation:

1. Physical Paper Records: Identifying client contracts, assessment forms, and handwritten clinical notes are kept as physical paper documents. These are securely locked inside a padlocked filing cabinet in a locked consulting room. They are never scanned or uploaded to cloud storage.
2. Digital Records: Electronic records on my computer are strictly limited to anonymised client reference codes, dates of sessions, and fee accounting entries. My computer is encrypted and password-protected.
3. Practice Telephone: Client telephone numbers are stored under anonymised first names on a dedicated practice phone secured with biometric PIN protection.

5. Online & Remote Sessions Best Practice

When sessions are conducted online via video conferencing, the following safeguards and professional standards apply to maintain safety and privacy:

5.1 Secure Platform:
Online video sessions are conducted via secure, end-to-end encrypted video conferencing platforms [Simon to confirm platform: e.g. Zoom with waiting room and encryption enabled / MS Teams / VSee]. I never use unvetted or unsecured consumer chat services.

5.2 Confidential Environment & Privacy:
To preserve therapeutic containment, both client and counsellor must connect from a private, confidential space where they cannot be overheard, seen, or interrupted by others. Using headphones is strongly advised. Sessions should not be conducted from public spaces, moving vehicles, or shared rooms.

5.3 No Recordings:
Audio or video recording of therapy sessions by either the client or the counsellor is strictly prohibited. This ensures complete freedom of expression, vulnerability, and mutual trust within the therapeutic space.

5.4 Emergency Safeguard for Remote Work:
Because we are not in the same physical room, before each online session you must confirm the physical address/location you are connecting from, along with up-to-date emergency contact details. This ensures I can contact emergency assistance or your local GP in the rare event of an acute medical or psychological emergency during a call.

5.5 Technical Failure Protocol:
If the video connection drops unexpectedly, we will pause and attempt to reconnect. If reconnection fails within 5 minutes, I will call you directly on your agreed telephone number to continue or rearrange the session.

6. Artificial Intelligence (AI) & Digital Ethics Policy

In accordance with the BACP Ethical Framework for the Counselling Professions (specifically Section 2.1(e) regarding digital tools and emerging technologies), I maintain a clear, transparent policy regarding Artificial Intelligence:

6.1 Relational, Human-Centred Therapy:
My therapeutic practice is person-centred and fundamentally human. Therapy relies on authentic, human-to-human empathy, active presence, and relational depth. I do not use AI chatbots, automated therapeutic tools, or AI avatars to conduct or evaluate therapy.

6.2 No Automated AI Recording or Transcription:
I never use AI-driven listening assistants, automated meeting bots (such as Otter.ai, Read.ai, or Zoom AI summaries), or real-time audio transcription tools during our sessions. No automated bot will ever enter our video calls.

6.3 Protection Against Generative AI Models:
I never input identifiable client dialogue, case notes, personal stories, or therapeutic reflections into open commercial Generative AI platforms (such as ChatGPT, Claude, or Copilot). Feeding client data into external AI models creates severe risks of data harvesting, model training, and privacy breaches that violate both UK GDPR and BACP ethical standards.

6.4 Human Clinical Judgment:
All clinical notes, case formulations, and therapeutic reflections are authored personally and exclusively by me. My clinical judgment, ethical responsibilities, and accountability remain entirely human.

7. Confidentiality & Exceptional Legal Limits

What you share in our sessions remains strictly confidential. I will never disclose your personal details or the contents of our discussions to family members, employers, or third parties without your explicit consent. There are only four rare and specific circumstances where confidentiality may be broken, in accordance with the law and professional ethics:

1. Risk of Serious Harm: If there is compelling reason to believe that you or another person is at immediate risk of serious physical harm or loss of life, I may need to contact emergency services or your GP. Wherever practically and safely possible, I will discuss this with you first.
2. Statutory Legal Obligations: Under UK legislation, I am legally required to disclose information relating to acts of terrorism, drug money laundering, or serious safeguarding concerns involving children or vulnerable adults.
3. Court Subpoena: In the rare event of receiving a formal, legally binding court order or subpoena.
4. Your Written Request: Where you provide express, written permission for me to share information with a third party (such as your GP, solicitor, or insurance provider).

8. Clinical Supervision (BACP Requirement)

In accordance with BACP ethical standards, all practicing counsellors attend regular monthly clinical supervision with an experienced, accredited supervisor. This ensures that my practice remains safe, effective, and ethically sound. During supervision, therapeutic material may be discussed, but all client work is presented with strict anonymity. No identifying details (such as names, addresses, or specific workplace details) are ever disclosed, and the supervisor is bound by the exact same strict confidentiality rules.

9. Professional Will / Clinical Executor

In line with BACP guidelines (GPiA 089), I maintain a Professional Clinical Will. In the unexpected event of my death, sudden severe illness, or incapacity that prevents me from contacting you myself, a designated, accredited fellow counsellor (Clinical Executor) will be granted restricted access to client contact details solely to inform you of my situation and discuss continuity of care. The Clinical Executor is bound by the same professional BACP code of ethics, and client contact lists for this contingency are reviewed and securely maintained on a monthly basis.

10. Communications & Appointment Administration

You and I will agree on your preferred communication method (phone, text, or email) during your initial session. I use these channels solely for practical matters: scheduling, confirming, or rescheduling appointments, and notifying you of any planned holidays or practice closures.

Please note that text messages and standard email are not end-to-end encrypted. For your privacy, sensitive personal thoughts and therapeutic reflections should be saved for our sessions rather than sent via text or email.

11. Record Retention & Secure Disposal

In accordance with professional indemnity insurance standards, BACP guidelines, and the Limitation Act 1980, client clinical notes, intake agreements, and session dates are securely retained for a period of seven (7) years [Simon to confirm: e.g. 7 years as required by professional indemnity insurance / 5 years] following the final date of your counselling work with me. After this period has elapsed, all physical paper records are permanently destroyed using cross-cut shredding, and digital entries (such as payment logs and phone entries) are permanently deleted.

12. Your Statutory Rights (UK GDPR)

Under the UK GDPR, you have the following rights regarding the personal data I hold:

1. Right of Access: You may request to see the personal information and clinical notes I hold about you.
2. Right to Rectification: You may request that any factual inaccuracies in your administrative records (such as an address or phone number) be corrected.
3. Right to Erasure: You may ask for your data to be deleted. Please note that ethical and legal obligations under professional indemnity insurance may require me to retain brief factual clinical notes for the standard retention period.
4. Right to Restrict Processing: You have the right to request restriction of your data under specific statutory conditions.

To request a copy of your records or discuss your personal data, please contact me directly. Requests will be addressed without charge and completed within one calendar month.

13. Queries & How to Contact Me or the ICO

If you have any questions, worries, or feedback about how your information is handled, please feel free to raise them with me during our sessions or via email. I am always happy to discuss this openly with you.

You also have the statutory right to contact the UK supervisory body for data protection:

Information Commissioner’s Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
Website: www.ico.org.uk

To discuss starting counselling or get in touch, please visit my Contact Page.