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Privacy Policy for Inis Ink Counselling

effective: 1 August 2026

Welcome to Inis Ink Counselling (“we”, “our”, or “us”). Your privacy is critically important to us and we are committed to protecting it through our compliance with this policy.

 

This privacy notice explains how and why Inis Ink Counselling collects, processes and protects your personal data. This policy applies to information collected on this website (https://www.inis-inkcounselling.co.uk – “our website”), information collected when you begin and use our services and information in email, text, and other electronic messages between us.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • by which you may be personally identified, such as name, email address, telephone number, or any other identifier by which you may be contacted online or offline ("personal information").

  • about the issues for which you want help (if you choose to share it).

  • that is about you but individually does not identify you.

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We collect this information:

  • directly from you when you provide it to us, usually via our contact page.

  • automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

 

Once you start accessing the services provided at Inis Ink Counselling, we collect additional information directly from you, usually at or before your first meeting, but also on an on-going basis throughout therapy. This includes:

  • Personal information through which you may be personally identified (such as name, postal address, email address, telephone number, date of birth, gp details, emergency contact details, etc.) 

  • Health and therapy-related information (such as presenting issues and reasons for seeking therapy, relevant medical and mental health history, risk assessments, outcomes and progress notes, session notes documenting our therapeutic work together) which is classified as “special category data” under Article 9(1) of the UK GDPR. As this data concerns your physical and mental health, it receives enhanced legal protection because of its sensitive nature.

  • Financial information (such as payment records, invoices and receipts related to your therapy sessions)

 

This data is collected when you first enquire about therapy via email, telephone or the website contact form, during the intake (usually first) meeting, when you complete assessment forms and we discuss your background and presenting issues, through our ongoing therapeutic conversations and/or when we communicate via email or telephone between sessions.

Personal data is never collected about you from third parties without your knowledge and consent.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • to present our Website and its contents to you.

  • to understand how our Website is being used.

  • to provide you with information, products, or services that you request from us.

  • to fulfill any other purpose for which you provide it.

  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

  • for any other purpose with your consent.

 

When someone visits our website, we use Google Analytics, a third-party service, to collect standard internet log information and details of visitor behaviour patterns to help us understand the number of visitors to various parts of the website. We process this information in a way that does not identify anyone, nor do we make (or allow Google to make) any attempt to find out who is visiting the website. The internet log information supports us to continually improve our service to you. We also use cookies to help the site work more efficiently and our cookies policy can be accessed here.

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Our website contains links to other organisations. This privacy policy does not cover how those organisations process personal information. You can read their privacy notices if you visit those websites.

Why we process your data – Lawful basis

According to the United Kingdom General Data Protection Regulation (UK GDPR), there must be a lawful basis for us to process your personal data. For the services provided by Inis Ink Counselling, the following legal grounds apply:

  • Article 6 basis (ordinary personal data): Processing your data is necessary to enact the therapeutic contract and for our services to fulfil that contract. 

  • Article 9 basis (special category data): According to Article 9(2)(h) UK GDPR, processing is necessary for the provision of health or social care treatment by a health professional. Also, according to the Data Protection Act (2018) Schedule 1 (in part 1 paragraph 2 – health or social care), data processing is carried out by a qualified counsellor subject to the professional obligation of confidentiality under the British Association for Counselling and Psychotherapy’s code of ethics and practice.

What we do with your information

Your personal information

Personal information you provide via the website’s contact page is encrypted and password-protected, stored on secure devices with access restricted solely to Debbie Innes (the “Data Controller”)

 

Personal information provided on paper is kept in a locked filing cabinet in a secure room, with access restricted solely to the Data Controller. Personal data provided throughout therapy and/or provided in the course of email or text communications between sessions is stored electronically in secure, encrypted and password protected folders and can only be accessed the Data Controller – or your therapist if this is a different person. 

 

Whilst you are actively accessing a service, contact notes of each meeting are created by your therapist. These are electronic, anonymised and saved within a password protected file within the secure IT system at Inis Ink Counselling. These notes are for the therapist’s use only and help them keep track of what is being discussed. During this time, your email address and/or telephone number may be used to contact you about your appointments or to share information that is pertinent to the service you are receiving. This could be via an email, telephone call or text message. Our email accounts are password protected, only accessible by the Data Controller or your therapist (if this is a different person), and any devises used are fully protected with anti-virus software and use password protection. Notes and communications are kept securely and as per our data retention periods outlined below.

 

After the applicable retention period expires for any information we hold (see below) paper records are shredded using a cross-cut shredder and electronic records are permanently deleted using secure deletion software. 

 

Your personal information is never sold or passed on to any third party organisations for the purposes of sales, marketing or research, and it is never used for any other purpose except for the administration of the services provided to you (i.e., to communicate about sessions, request additional sessions and process payments for services provided). The only exception to this would be if you offered or we requested feedback about our service provision for the purposes of putting anonymised feedback on our website. We would never do this without your express permission and consent and you would not be identifiable from any feedback published on the website.

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Professional obligations and Continuing Professional Development (CPD)

Therapists and counsellors at Inis Ink Counselling are registered with the BACP, therefore clinical supervision is required as part of our professional practice. This professional requirement ultimately benefits you because it ensures the quality of therapy provided to you.

 

Clinical supervision requires us to discuss therapeutic work with our supervisor to help us reflect on our work, maintain professional standards and ensure you are provided with the best possible care. Within clinical supervision, we never share your name or any identifying details with our supervisor and use anonymised case material or create pseudonyms for case materials. Clinical supervisors who work with us are qualified professionals bound by both the same confidentiality obligations as us as well as their own professional body’s ethical framework.

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Payment information

Payment information is anonymised in financial income reports. These reports will hold only unique client reference numbers and no personal information. We are required by the HMRC to retain this information for six years after the end of the financial year.

 

If your sessions are paid for or arranged via a third party, (e.g. your employer, a friend, or a family member), the only information shared about your counselling sessions will be the dates and times of sessions attended/missed. Any details about what is discussed in sessions is confidential between you and us and your written consent would be required for us to share any information with a third party.

Confidentiality, sharing and protecting your data

As noted above, your personal data is not shared with third parties, except insofar as it is required for you to be provided with a service (e.g., with insurance companies to request additional sessions; to process payments; within clinical supervision, etc.). Everything you discuss with your therapist is confidential, however it is important to note there are limits and exceptions to this. These exceptions involve concerns around your safety or the safety of others (i.e., if we believe there is a serious and imminent risk of harm to you or another person; if we become aware of safeguarding issues involving children or vulnerable adults) or legal requirements (if we are ordered by a court to disclose information or if disclosure is required by law). In all cases, we will try to discuss this with you first and explain what information must be shared and why, unless doing so would incur risk for others. Where possible, only the minimum information necessary will be shared and you will be informed afterward of any disclosure made.

 

We conduct all online and telephone sessions in quiet, private and confidential settings. Only video-calling platforms offering end-to-end encryption are used to provide remote sessions to ensure maximum privacy. Please note, however, that we cannot be held responsible for any breaches that occur due to failures in this technology.

 

Some services we use process some of your data (e.g., Wix, Zoom, Microsoft 365 among others), all of which are bound by a data processing agreement that requires them to protect your data appropriately. Links to their privacy policies are available upon request.

Your data protection rights 

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

  • Your right to be informed (i.e., you have the right to know how your data is being used). This privacy policy fulfils that purpose.

  • Your right of access. You can make a Subject Access Request (SAR) to the data controller requesting a copy of what personal data we hold about you. Under the Data (Use and Access) Act 2025, we will conduct a reasonable and proportionate search to locate your data and respond within one month of your request.

  • Your right to rectification (i.e., you can ask us to correct any inaccurate or incomplete data we hold about you).

  • Your right to erasure (i.e., in certain circumstances, you can ask us to delete your personal data). However, this right does not apply where records are required to be retained (through the Limitation Act 1980, professional indemnity insurance requirements or other legal obligations).

  • Your right to restriction of processing (i.e., you can ask us to limit how your data is used in certain circumstances, for instance while a complaint is being investigate).

  • Your right to data portability (i.e., you can request that your data be transferred to another service provider in a commonly used format where technically feasible).

  • Your right to object to processing (i.e., you can object to certain types of processing, though this may not apply to therapy records processed under contract or health care provisions).

 

To exercise your rights, you can contact the data controller at debbie [at] inis-inkcounselling.co.uk. All requests will be responded to within one month.

How long we keep information

Your personal data is kept only as long as is necessary to fulfil the purposes for which it was collected or as long as required by law and professional standards. Therefore, 

  • website enquiries will be kept for 12 months through legitimate interests to enable us to respond to enquiries; 

  • therapy records will be kept for 7 years after the date of our last session in line with the Limitation Act 1980 and standard professional indemnity insurance requirements; and

  • financial records will be kept for 6 years after the date of our last session due to the HMRC legal requirement.

 

For more information on how long we store your personal information or the criteria we use to determine this please contact the data controller as identified above. As noted above, once applicable retention period expires for any information we hold, paper records are shredded using a cross-cut shredder and electronic records are permanently deleted using secure deletion software. 

How to complain

If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

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Email: debbie [at] inis-inkcounselling.co.uk

Telephone: 07864 818 447

 

We take all complaints seriously and will respond promptly and thoroughly.

 

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can escalate your complaint to the Information Commissioner’s Office. 

Changes to this policy

This privacy policy is reviewed annually (see effective date above) and whenever practices change. If we make significant changes that affect how your personal data is handled, you will be informed directly by the data controller.

Contact

If you have any questions about this privacy policy or how your personal data is handled, please contact the data controller: debbie [at] inis-inkcounselling.co.uk.

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