Privacy Notice
St Martin’s Counselling
Last reviewed: 13th August 2026
Next review due: 12th August 2027
Charity number: 1094458
Registered address: Edgbaston Street, Birmingham. B5 5BB
Privacy contact: admin@smchh.co.uk
Telephone: 0121 600 6025
Summary
St Martin’s Counselling collects and uses personal information so that we can respond to enquiries, assess whether our service is suitable, arrange counselling, provide safe support, manage appointments and payments, and meet our safeguarding, legal and professional responsibilities.
Because we provide counselling, some of the information we hold may be sensitive. This can include information about your mental health, wellbeing, personal circumstances, risk, relationships and support needs. We treat this information carefully and restrict access to those who need it for service, clinical, safeguarding, governance or legal reasons.
Counselling is confidential, but confidentiality is not absolute. We may need to share information if there is a serious risk of harm, a safeguarding concern, a legal requirement, or another serious professional responsibility.
We do not sell your personal information. We only use it for legitimate service, clinical, operational, legal and governance purposes.
The full Privacy Notice below explains what we collect, why we use it, who we may share it with, how long we keep it, and your rights.
Full Privacy Notice
1. About this notice
This Privacy Notice explains how St Martin’s Counselling collects, uses, stores and protects personal information. It applies to: people enquiring about counselling;
clients using our counselling service;
people referred to us by another organisation or professional;
website users;
referrers, professionals and partner organisations.
We aim to be clear and transparent about how we use personal information. The Information Commissioner’s Office states that organisations must tell people why their personal data is used, how long it is kept, and who it may be shared with.
2. Who is responsible for your information?
St Martin’s Counselling is the data controller for the personal information we collect and use. This means we decide why and how personal information is processed. Organisation: St Martin’s Centre for Health and Healing / St Martin’s Counselling
Charity number: 1094458
Address: Edgbaston Street, Birmingham. B5 5BB
Email: admin@smchh.co.uk
Telephone: 0121 600 6025
For privacy or data protection queries, please contact: admin@smchh.co.uk
We do not have a designated Data Protection Officer. Data protection matters are overseen by the Operations Lead Ryan Peters who can be contacted via the details above
3. What information we collect
We only collect information that is necessary for our counselling service and related administration. We may collect:
Contact and identity information
name;
date of birth;
address;
email address;
telephone number;
emergency contact details, where appropriate.
Enquiry and booking information reason for contacting us;
appointment preferences;
counselling pathway or fee option;
attendance, cancellations and appointment history;
correspondence with us.
Counselling and wellbeing information information you provide before, during or after counselling;
relevant mental health, wellbeing or personal circumstances;
presenting issues or support needs; assessment information; brief counselling notes;
risk or safeguarding information;
outcome measures or feedback, where used.
Payment information
fee level;
payment status;
invoices, receipts and transaction records; limited payment information needed to manage fees.
We do not usually store full card details ourselves.
Online payments are normally handled by our payment provider.
Referral information
Where another organisation or professional refers you, we may receive relevant information from them, such as contact details, reason for referral, risk information, support needs, or funding arrangements.
Website information
When you use our website, limited technical information may be collected, such as IP address, browser type, device information, pages visited and cookie or analytics information where enabled.
Some cookies are necessary for the website to function. These may be used without your consent where they are essential to provide the website or service you have requested.
We also use analytics cookies, including Google Analytics, to help us understand how visitors use our website and service pages. This may include limited information about whether someone visits key pages, starts or completes our eligibility screener, and reaches the booking page. The legal basis for analytics cookies is your consent, given via our cookie banner.
Analytics cookies are used to help us improve the website, understand where people may be dropping out of the process, and make access to counselling clearer and easier.
We do not use Google Analytics to collect or send your name, email address, telephone number, client reference, screening answers, free-text responses, risk information, health disclosures, or reasons why someone may not be eligible for the service.
We do not log failed eligibility screener outcomes in Google Analytics.
Analytics data may be transferred to and processed on Google's servers outside the UK. Google uses appropriate contractual safeguards for such transfers.
You can choose whether to accept or reject analytics cookies using our cookie banner or cookie settings tool. You can also change your browser settings to block or delete cookies, although some parts of the website may not work properly if necessary cookies are disabled.
4. Special category data
Some of the information we collect is sensitive under data protection law. This may include health, mental health, wellbeing, risk, safeguarding or other counselling-related information. This is known as special category data. The ICO explains that special category data needs additional protection and that organisations must identify both a lawful basis under Article 6 of UK GDPR and a separate condition under Article 9. We only collect and use this information where it is necessary, proportionate and relevant to the service we provide.
5. Why we use your information
We use personal information to: respond to enquiries; assess whether our service is suitable;
arrange and manage counselling appointments; allocate clients to suitable counsellors or practitioners; provide counselling safely and appropriately;
keep appropriate counselling records;
manage risk, safeguarding and professional responsibilities;
manage fees, payments, cancellations and attendance;
communicate with you about appointments or service matters; respond to complaints, concerns or legal issues; supervise and support counsellors;
monitor service quality and outcomes;
report anonymised or aggregated information to trustees, funders or commissioners;
meet legal, regulatory, insurance and governance duties. We do not use your personal information for purposes unrelated to our counselling service unless we have a lawful reason to do so.
6. Our lawful basis for using personal information
Under UK GDPR, we must have a lawful basis for using personal information. Depending on the situation, we may rely on:
Purpose
Likely lawful basis
Responding to enquiries
Legitimate interests and/or steps before entering into a service arrangement
Arranging and providing counselling
Contract and/or legitimate interests
Managing fees and payments
Contract and legal obligation
Keeping appropriate counselling records
Legitimate interests and/or provision of health or social care
Safeguarding and serious risk management
Legal obligation, vital interests, legitimate interests or substantial public interest, depending on the circumstances
Handling complaints, incidents or legal claims
Legitimate interests, legal obligation and/or legal claims
Service monitoring and reporting
Legitimate interests, usually using anonymised or aggregated data where possible
Sending newsletters or marketing
Consent, where required
Where we use special category data, we will also rely on an Article 9 condition. This may include provision of health or social care, safeguarding or substantial public interest, legal claims, explicit consent where appropriate, or vital interests in serious circumstances.
7. Consent and confidentiality
Counselling is confidential, but confidentiality is not absolute. We will normally ask you to agree to our counselling terms before counselling begins. This helps explain how the service works, including confidentiality, attendance, fees and information sharing.
However, we do not rely only on consent for all data protection purposes. In many cases, we need to use information because it is necessary to provide a safe counselling service, manage the organisation, meet legal duties, or protect people from harm.
We may need to share information without your consent where:
there is a serious risk of harm to you or another person;
there is a safeguarding concern involving a child or adult at risk;
we are required to do so by law, court order or another legal process;
information indicates terrorism, serious crime or significant public safety concerns; we need clinical supervision, safeguarding advice or internal professional guidance;
we need to respond to a serious complaint, incident, insurance matter, legal claim or regulatory issue.
Where possible and safe, we will try to discuss this with you before sharing information. This may not always be possible.
8. Counselling notes and records
Counsellors keep brief and relevant records of counselling work. These may include: session dates;
brief notes about themes discussed; assessment information; relevant risk or safeguarding information; agreed actions or signposting;
attendance and cancellation history;
outcome measures, where used.
Counselling notes are not intended to be a full transcript of sessions.
Access to counselling records is restricted to people who need the information for service, clinical, safeguarding, governance, legal or professional reasons.
9. Who we may share information with
We only share personal information where there is a legitimate reason to do so. We may share relevant information with:
your allocated counsellor or practitioner;
clinical supervisors;
service managers; safeguarding leads;
administrative staff involved in bookings, payments or service delivery;
IT, clinical record, booking, website or payment system providers;
emergency services, NHS services, GPs or crisis services where necessary; local authority safeguarding teams;
funders or commissioners, usually in anonymised or aggregated form; insurers, legal advisers or professional advisers where necessary;
regulators, courts or public authorities where legally required.
We aim to share the minimum necessary information.
10. Systems and service providers
We use secure systems and service providers to help run the counselling service. These may include systems for: clinical records and appointment management; booking and forms; online counselling or video appointments; email and office administration;
payment processing;
website hosting and analytics.
Current or possible systems may include Cliniko, Stripe, Microsoft 365, booking tools, website providers and secure form systems. Where a third-party provider processes personal information on our behalf, we expect them to process it securely, lawfully and only for authorised purposes.
11. International processing and transfers
Some of the service providers we use for our website, appointment bookings, communications, payments and IT systems process personal information outside the United Kingdom.
Information entered into our online appointment booking system is stored in the United States. This may include your name, contact details, appointment and practitioner details, booking-form responses and payment transaction information. Authorised technical support teams or subprocessors may also access information from outside the United Kingdom where this is necessary to provide or support the service.
Counselling notes and assessment records are stored in our UK-hosted clinical records system and are not held in our online booking system.
Where personal information is processed outside the United Kingdom, we use providers whose arrangements include safeguards recognised under UK data protection law. These may include UK adequacy regulations, such as the UK–US Data Bridge where applicable, or approved contractual safeguards such as the UK Addendum to the EU Standard Contractual Clauses.
You may contact us using the details in section 2 for further information about the safeguards applying to a particular service provider.Some providers may process data outside the UK. Where any current system stores data outside the UK that Standard Contractual Clauses (or UK Addendum) are used where required.
12. How long we keep information
We keep personal information only for as long as necessary. The ICO says privacy information should explain retention periods or, where a fixed period is not possible, the criteria used to decide how long information is kept. Our usual retention approach is:
Type of record
Usual retention period
Enquiries that do not progress to counselling
12 months
Adult counselling records
7 years after last contact
Safeguarding records
10 years, longer depending on the issue
Complaints, incidents and legal matters
7 years after closure, or longer where required
Financial and payment records
6 years plus current financial year
Website analytics
14 months
Referrer or professional contact details
For as long as needed for the relationship or service purpose
When information is no longer needed, we will securely delete, anonymise or archive it in line with our retention procedures.
13. Anonymised information and reporting
We may use anonymised or aggregated information to monitor, evaluate and improve the service.
This may include:
number of clients supported;
number of sessions delivered;
waiting times; attendance and cancellation rates;
broad presenting issues;
outcome measures;
broad demographic information, where collected.
Anonymised information does not identify you personally.
We may use anonymised or aggregated information in reports to trustees, funders, commissioners, regulators or the public.
14. Your rights
You have rights under data protection law. These include: the right to be informed about how your information is used;
the right to access personal information we hold about you;
the right to ask us to correct inaccurate information;
the right to ask us to delete information in certain circumstances;
the right to ask us to restrict processing in certain circumstances;
the right to object to certain processing; the right to data portability in certain circumstances;
rights relating to automated decision-making, where applicable.
“We do not use automated decision‑making or profiling that has a legal or similarly significant effect.”
These rights are not absolute. For example, we may need to keep some information for safeguarding, legal, clinical governance, insurance or professional accountability reasons.
To exercise your rights, contact: Email: admin@smchh.co.uk
Post: Edgbaston Street, Birmingham. B5 5BB
We may need to confirm your identity before responding.
15. Subject access requests
You can ask for a copy of personal information we hold about you. This is called a subject access request. We will usually respond within one month. The ICO explains that individuals have the right to access and receive a copy of their personal data, although some exemptions may apply. We may not be able to provide all information if, for example, disclosure would: identify another person; create a serious risk of harm; affect safeguarding enquiries; disclose legally privileged information; conflict with another legal obligation.
16. Keeping information safe
We take reasonable steps to protect personal information from loss, misuse, unauthorised access or inappropriate disclosure. These steps may include: secure systems;
password protection;
role-based access controls; confidentiality agreements; staff, counsellor and volunteer guidance;
safeguarding and data protection procedures;
secure record-keeping; breach reporting procedures.
No system is entirely risk-free, but we work to protect information in a way that reflects the sensitivity of counselling data.
17. Email, telephone and online communication
We use email as our main way of communicating with you about your counselling. This includes booking confirmations, links to pre-session and assessment forms, session reminders, scheduling changes, payment confirmations and general administrative contact. Booking confirmations are sent automatically by our online booking system.
A working email address is necessary to book and receive counselling with us. We use your email address for these purposes because the processing is necessary to take steps at your request before entering into a service arrangement and to provide and administer the counselling service you have asked for. Where the contract basis does not apply, we rely on our legitimate interests in responding to enquiries and administering the service, provided that those interests are not overridden by your rights and interests.
We do not rely on consent for essential service-related emails, and these emails cannot be switched off while you are using the service. If you do not provide and maintain a working email address, we may be unable to accept or manage your bookings.
With your consent, we can also send session reminders, scheduling changes and general administrative messages by text, in addition to email. You can withdraw your consent to text messages at any time by contacting us using the details in section 2. Withdrawing consent to text messages will not stop essential email communications.
We may telephone you where reasonably necessary about an enquiry, appointment, payment or another service-related matter.
Email and text messages cannot be guaranteed to be completely secure. We take appropriate steps to protect your information and keep routine communications brief, avoiding unnecessary sensitive or clinical information. Where possible, please do not send sensitive clinical information by ordinary email or text message; contact us if you need to agree a more suitable way to share it.
Please tell us promptly if your email address or telephone number changes.
18. Marketing and newsletters
We will not send you marketing emails unless we have a lawful basis to do so. Where consent is required, we will ask for your consent. You can withdraw consent or unsubscribe at any time. Service-related messages, such as appointments, payments or important service updates, are not marketing.
19. Referrers and professionals
If you are a referrer, professional, partner organisation or funder, we may process your contact details and professional information to manage referrals, respond to enquiries, coordinate services, manage contracts, or meet governance and reporting requirements.
Please do not send us sensitive personal information about someone else unless there is a lawful and appropriate reason to do so.
20. Adults-only service
Our counselling service is for adults aged 18 and over. “We do not knowingly process personal data of children for counselling.” If a child or young person contacts us and there appears to be a risk or safeguarding concern, we may take appropriate action, including signposting or contacting relevant services where necessary.
21. Complaints
If you are concerned about how we have used your personal information, please contact us first so we can try to resolve the issue.
Email: admin@smchh.co.uk
Post: Edgbaston Street, Birmingham. B5 5BB
You also have the right to complain to the Information Commissioner’s Office, the UK regulator for data protection.
22. Changes to this notice
We may update this Privacy Notice from time to time. The latest version will be published on our website.