Accessibility Note

This policy is available in alternative formats.
If you need this information in a different format, please contact Echo at info@theechosociety.org.uk.

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1. Purpose of This Policy

This policy explains how Echo Society Ltd (“Echo”, “we”, “us”) retains, stores, reviews, and securely disposes of the information we hold in connection with:

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• community activities

• workshops, training, and events

• support groups

• volunteering

• fundraising

• campaigns and outreach

• enquiries

• counselling intake and allocation

• safeguarding coordination

• continuity planning

• organisational operations

It also explains how retention interacts with the responsibilities of Associate Counsellors, who are independent Data Controllers for clinical records.

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This policy supports the Echo Privacy Notice and the Counselling & Therapeutic Records Privacy Notice.

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2. Scope

This policy applies to:

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• all Echo‑held service‑level information

• safeguarding and continuity records

• administrative and organisational records

• volunteer and donor information

• event and workshop information

• website and communication records

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This policy does not apply to:

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• clinical notes

• therapeutic records

• session content

• modality‑specific documentation

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These are held by Associate Counsellors, who follow their own retention schedules.

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3. Controller Responsibilities

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3.1 Echo as Data Controller

Echo is the Data Controller for:

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• service‑level counselling pathway information

• allocation information

• safeguarding coordination records

• continuity planning information

• administrative and organisational records

• volunteer and donor information

• event, workshop, and group registrations

• campaign and outreach participation

• website and communication data

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3.2 Associate Counsellors as Independent Controllers

Associate Counsellors are independent Data Controllers for:

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• clinical notes

• therapeutic records

• session content

• clinical retention

• clinical SAR responses

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Echo does not determine retention for clinical records.

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4. Principles of Retention

Echo retains information only for as long as necessary for:

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• service delivery

• safeguarding

• continuity

• legal obligations

• organisational needs

• financial and audit requirements

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Echo will periodically review retained information to ensure:

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• records are not kept longer than necessary

• retention periods remain appropriate

• information remains accurate and relevant

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Retention periods are based on:

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• UK GDPR

• safeguarding guidance

• insurance requirements

• operational needs

• proportionality and data minimisation

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5. Retention Schedule (Echo‑Held Information)

Retention periods shown in this schedule are maximum retention periods unless a shorter period is appropriate or a legal hold applies.

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5.1 Counselling Pathway (Service‑Level Only)

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Intake and Allocation Information

Retention: Up to 3 years
Reason: Service continuity, safeguarding context, complaints handling

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Continuity Planning Information

Retention: Up to 3 years
Reason: Continuity and safeguarding

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Safeguarding Coordination Records

Retention: 6 years
Reason: Legal obligations, safeguarding audit trail

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5.2 Community Activities

Workshops, Training, Events

Retention: Up to 2 years
Reason: Administration, reporting, safeguarding context

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Support Groups

Retention: Up to 2 years
Reason: Group administration, safeguarding context

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5.3 Volunteering

Volunteer Applications and Records

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• Successful volunteers: Up to 3 years after role ends

• Unsuccessful applicants: 6 months
  Reason: Administration, safeguarding, audit

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5.4 Campaigns and Outreach

Campaign Participation

Retention: Up to 2 years
Reason: Administration, engagement tracking

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5.5 Communications and Enquiries

General Enquiries

Retention: Up to 1 year
Reason: Administration, follow‑up

 

Email Communications

Retention: Up to 3 years
Reason: Operational continuity, safeguarding context

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5.6 Website and Technical Data

Website Analytics and Logs

Retention: Up to 1 year
Reason: Security, performance monitoring

 

5.7 Organisational Records

Policies, Governance, and Operational Documents

Retention: Retained for governance, audit, legal, historical, or organisational purposes and reviewed periodically to determine ongoing necessity.
Reason: Governance and audit

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6. Retention Schedule (Associate‑Held Clinical Records)

Associate Counsellors retain:

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• clinical notes

• therapeutic records

• session content

• modality‑specific documentation

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Retention: Determined by the Associate Counsellor in line with:

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• professional body requirements

• insurance requirements

• legal obligations

• safeguarding considerations

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Echo does not set or manage clinical retention periods.

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7. Secure Disposal

Echo disposes of information securely using:

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• secure digital deletion

• removal from encrypted systems

• secure shredding for paper records

• permanent deletion from cloud storage (including trash folders)

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Where appropriate, Echo may maintain records of disposal activities to demonstrate compliance with retention obligations.

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Echo does not dispose of clinical records — this is the responsibility of the Associate Counsellor.

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8. Legal Hold

If information is required for:

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• safeguarding investigations

• legal claims

• regulatory requests

• complaints handling

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Echo may suspend deletion until the matter is resolved.

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Legal hold applies only to Echo‑held information.
Associate Counsellors manage legal hold for their own clinical records.

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9. Subject Access Requests (SARs)

 

Echo‑held information​

Requests should be sent to Echo.
Echo will provide only the information it holds.

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Clinical records

Requests must be sent to the Associate Counsellor.
Echo cannot access or release clinical notes.

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This reflects the distinction between the information Echo holds and the clinical information managed independently by your counsellor.

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10. Roles and Responsibilities

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Echo

• Maintains this policy

• Ensures secure retention and disposal of Echo‑held information

• Responds to SARs for Echo‑held information

• Coordinates safeguarding and continuity records

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Associate Counsellors

• Maintain their own retention schedules

• Securely store and dispose of clinical records

• Respond to SARs for clinical information

• Follow their own professional and legal obligations

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11. Updates to This Policy

Echo may update this policy from time to time.
The version that applies is the one published on our website on the day you use our services.

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