Accessibility Note

This Privacy Notice is available in alternative formats.
If you need this information in a different format, please ask your counsellor or contact Echo for support.

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1. Who This Notice Is For

This Privacy Notice explains how your Associate Counsellor (“your counsellor”) uses and protects your clinical and therapeutic information.

 

Your counsellor is an independent Data Controller for:

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• clinical notes

• therapeutic records

• session content

• assessment information

• modality‑specific documentation

• clinical retention

• clinical Subject Access Requests (SARs)

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Echo does not hold or manage these records.

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In this notice, “your counsellor” refers to the Associate Counsellor providing your therapy.

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2. Who Your Counsellor Is

Your counsellor is an independent practitioner who provides therapy through Echo’s counselling pathway.

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They are responsible for:

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• their own clinical practice

• their own therapeutic record‑keeping

• their own data protection compliance

• their own ICO registration

• their own retention schedule

• responding to SARs for clinical information

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Echo provides the service‑level pathway (intake, allocation, safeguarding coordination, continuity planning).
Echo is not responsible for the counsellor’s clinical records, clinical decisions, or therapeutic record‑keeping.

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Your counsellor will provide their:

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• full name

• practice address (or secure contact route)

• ICO registration number

• preferred contact method for data protection matters

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3. What This Notice Covers

This notice explains how your counsellor uses information relating to:

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• your therapy sessions

• your clinical notes

• your therapeutic history (as disclosed in therapy)

• your goals, themes, and progress

• risk information discussed in sessions

• supervision discussions (with identifying information limited to what is reasonably necessary)

• any information you share as part of the therapeutic process

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This notice does not cover Echo’s service‑level information.
For that, see the Echo Privacy Notice.

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4. Information Your Counsellor Collects

Your counsellor may collect and maintain:

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4.1 Clinical and therapeutic information

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• session notes

• themes, goals, and therapeutic focus

• information you share during therapy

• risk‑related information

• wellbeing information

• relevant background information you choose to disclose

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4.2 Administrative information

• your name

• contact details

• appointment history

• payment information (if applicable)

• communication records related to therapy

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4.3 Special category data

Your counsellor may process special category data, including:

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• health information

• mental health information

• information about experiences of abuse

• risk‑related information

• safeguarding information

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Where special category data is processed, your counsellor does so in accordance with UK GDPR, including the additional protections that apply to sensitive personal information, and always limits this to what is necessary.

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5. How Your Counsellor Uses Your Information

Your counsellor uses your information to:

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• provide therapy

• maintain accurate clinical records

• understand your needs and therapeutic goals

• ensure safe and ethical practice

• manage risk and safeguarding concerns

• arrange appointments and communication

• meet professional, ethical, and legal obligations

• participate in clinical supervision (with identifying information limited to what is reasonably necessary)

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Your information is never used for marketing.

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6. Lawful Bases for Processing

Your counsellor relies on:

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Legitimate Interests

For the provision of therapy, maintaining clinical notes, and participating in supervision.

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Contract

For administrative aspects of therapy such as appointments, communication, and invoicing.

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Legal Obligation

Where required by law (e.g., safeguarding).

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Vital Interests

Where someone is at risk of serious harm.

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Explicit Consent

Where required for specific therapeutic processes or information sharing.

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Your counsellor will explain which lawful basis applies if you ask.

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7. Confidentiality

Everything you share in therapy is treated with care and confidentiality.

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Your counsellor will not share your information unless:

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• you request or consent to sharing

• there is a serious and immediate risk of harm

• there is a safeguarding concern involving a child or vulnerable adult

• they are legally required to do so (e.g., court order)

• sharing is necessary to protect vital interests

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Where possible, your counsellor will discuss this with you first.

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8. Supervision

Your counsellor receives regular professional supervision to support safe and ethical practice.

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In supervision:

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• identifying information is limited to what is reasonably necessary

• only relevant information is discussed

• supervisors are bound by confidentiality

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Supervision does not involve sharing your clinical records with Echo.

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9. Who Your Counsellor May Share Information With

Your counsellor may share information with:

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• emergency services (if someone is at risk)

• safeguarding agencies (where required)

• their clinical supervisor

• legal authorities (if required by law)

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Your counsellor does not share information with Echo except:

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• minimal information necessary for safeguarding coordination

• minimal information necessary for continuity planning

• minimal information necessary for Echo’s organisational responsibilities

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Echo does not receive your clinical notes.

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10. How Long Your Counsellor Keeps Your Information

Your counsellor keeps clinical records in line with:

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• their professional body requirements

• their insurance requirements

• their own retention schedule

• applicable legal and safeguarding obligations

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Retention periods may vary between counsellors.
Your counsellor will provide information about their retention arrangements on request.

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Echo does not determine retention for clinical records.

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11. Your Rights

You have rights under UK GDPR, including:

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• access to your clinical records

• correction of inaccurate information

• deletion (where applicable)

• restriction

• objection

• portability (where applicable)

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Subject Access Requests (SARs)

For clinical records, contact your counsellor directly.
Echo cannot access or release your therapeutic information.

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Your counsellor will explain what they hold and how to request it.

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Your right to complain

If you are unhappy with how your information has been used, you can complain to:

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Information Commissioner’s Office (ICO)
www.ico.org.uk

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You can also raise concerns directly with your counsellor.

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12. Security

Your counsellor is responsible for keeping your information secure, including:

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• secure storage of clinical notes

• password‑protected systems

• encrypted devices (where applicable)

• secure communication practices

• safe disposal of records after retention ends

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Echo does not store or manage your clinical records.

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13. Contact Details

Your counsellor will provide:

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• their name

• their practice address or secure contact route

• their ICO registration number

• their preferred contact method for data protection matters

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If you cannot reach your counsellor, Echo can help you contact them but cannot access your clinical information.

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14. Updates to This Notice

Your counsellor may update this Privacy Notice from time to time.
The version that applies is the one provided to you at the start of therapy or the most recent version shared with you.

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