Privacy Statement
Last updated: 21 October 2026
Your privacy matters to me. This statement explains, in plain language, what personal information I collect when you contact me or have counselling with me, why I use it, how I keep it safe, and what rights you have.
I am committed to treating your information with care and confidentiality, while also meeting my responsibilities under UK data protection law and my professional obligations
1. Who is responsible for your information?
Peter Soper trading as Codacounselling is the data controller for your personal information.
Email: contact@codacounselling.com
ICO registration: ZB635097
If you have any questions about how I use your information, or you want to exercise one of your data protection rights, you can contact me using the email address above.
2. What information might I collect?
The information I collect will depend on your circumstances and what is needed to provide counselling safely and appropriately.
This may include:
• your name and contact details;
• your address or date of birth, where necessary;
• GP or emergency contact details, where relevant;
• information you give me when you make an enquiry or during an assessment;
• referral information, where applicable;
• appointment and attendance information;
• emails, messages and other correspondence;
• payment and invoicing information;
• your counselling agreement and preferences about how I contact you; and
• counselling records and information relevant to safeguarding, serious risk, complaints, legal matters or insurance.
Counselling can involve very personal information. You may talk to me about your physical or mental health, disability, neurodivergence, relationships, sexuality, trauma, risk or other parts of your life. Some of this information is special category data under UK data protection law and therefore has additional legal protection.
Where it is necessary and lawful, I may also receive information from a referrer, another professional, an emergency contact or a relevant authority.
3. Why do I use your information?
I use your information only where there is a lawful reason to do so. This may include:
• responding to your enquiry and deciding whether I can offer you counselling;
• arranging and providing counselling;
• keeping appropriate professional records;
• contacting you about appointments, cancellations or changes to the service;
• dealing with payments, invoices and accounts;
• meeting legal and professional responsibilities;
• responding to safeguarding concerns or serious risks;
• dealing with complaints, legal matters or insurance matters; and
• keeping my practice and website secure and functioning properly
I try to collect and use only the information that is reasonably necessary for these purposes.
4. What is the legal basis for using your information?
Data protection law requires me to have a lawful basis for using personal information. The basis depends on what I am doing with the information.
Depending on the circumstances, I may rely on:
• Article 6(1)(b) – contract: where processing is necessary to take steps at your request before entering into an agreement or to provide counselling under an agreement;
• Article 6(1)(c) – legal obligation: where I need to process information to comply with a legal obligation;
• Article 6(1)(f) – legitimate interests: where processing is necessary for legitimate interests such as running a safe and properly administered practice, maintaining appropriate records, protecting security or dealing with legal claims, provided your rights and freedoms do not override those interests;
• Article 6(1)(d) – vital interests: in genuinely exceptional circumstances where processing is necessary to protect someone's life; and
• Article 6(1)(a) – consent: where consent is the appropriate lawful basis for a particular use of information.
Consent to counselling is not automatically the legal basis for everything I do with your information. For example, some records may need to be kept because of legal, professional, insurance or other legitimate requirements.
Information about health and other special categories
Information about health, including mental health, is classed as special category data. This means that, in addition to an Article 6 lawful basis, I also need a separate condition under Article 9 of the UK GDPR.
The appropriate Article 9 condition depends on the particular purpose and circumstances. Depending on the situation, this can include explicit consent, legal claims, vital interests, safeguarding, health or social care, or a substantial-public-interest condition.
There is a specific “Counselling etc.” condition in paragraph 17 of Schedule 1 to the Data Protection Act
2018. It can apply to confidential counselling where its statutory requirements are met, including circumstances where processing takes place without consent and the processing is necessary for a substantial public interest. It is not an automatic basis for every use of counselling information.
I identify and document the Article 6 basis and Article 9 condition that apply to the relevant processing activity, including any additional requirements under Schedule 1 of the Data Protection Act 2018.
5. Confidentiality
Confidentiality is a fundamental part of counselling. I will normally keep what you tell me private and, where appropriate, discuss a proposed disclosure with you first.
There are, however, some circumstances in which information may need to be shared without your consent. This could be where:
• I am required to do so by law or a valid legal order;
• there is a serious and significant risk of harm;
• I need to take appropriate action to safeguard a child or an adult at risk;
• there is a specific statutory reporting duty;
• information is needed in connection with a legal claim or court process; or
• disclosure is necessary and lawful in response to a complaint or professional regulatory matter.
An allegation of past abuse or a crime does not automatically mean that I must make a report in every situation. I will consider the circumstances carefully, including your wishes, relevant legal duties, the safety of others and what information is actually necessary.
Where appropriate, I will keep a record of the reasons for a disclosure decision and what information was shared.
6. Continuity if I become unable to work
I have arrangements intended to support continuity of care if I die or become unexpectedly unable to continue working.
If someone needs to assist with those arrangements, they will only be given access to information that is reasonably necessary for that purpose and will be expected to respect appropriate confidentiality and legal requirements.
This may include names and safe contact details and, where necessary, limited records or instructions.
Your counselling records will not automatically be passed to another counsellor. Any further sharing would need appropriate authorisation or another lawful basis.
7. How I keep your information safe
I use reasonable physical and electronic security measures to protect your information. These include access controls, password protection, secure storage and limiting the amount of confidential information held or shared.
Access to information is restricted to people who genuinely need it for a justified purpose.
Email, telephone calls and text messages are not completely risk-free. I will agree appropriate ways of contacting you, where practicable. Please avoid putting sensitive clinical information into ordinary messages unless we have agreed that the method is suitable.
Where counselling takes place online, I may use video or telephone platforms. I take reasonable steps to consider the security and suitability of the platforms I use, but no electronic communication system can be guaranteed to be completely risk-free.
8. Other organisations and service providers
I use some third-party services to run my practice and website. Depending on what is needed, these may include services for:
• website hosting;
• email;
• video or telephone communications;
• telecommunications;
• banking and payments;
• document storage; and
• accounting.
My current providers may include Wix, Google/Gmail and Zoom. Depending on the service, these organisations may process information on my behalf or may act as independent data controllers.
I do not sell your personal information.
Some providers may process information outside the UK. If UK data protection law requires safeguards for an international transfer, I will use an appropriate lawful transfer mechanism and safeguards, such as UK adequacy regulations or appropriate contractual safeguards.
9. Website and cookies
When you use my website, some technical information may be processed so that the website can operate and remain secure.
The website and services embedded within it may use essential cookies and, depending on the website configuration, other cookies or similar technologies.
Where non-essential cookies require your consent, I will provide appropriate information and obtain consent where required.
I will review the cookie information when the website or its integrations change.
10. Artificial intelligence and digital tools
I may use digital tools, including AI tools, for general administration, drafting, planning and other work that does not involve confidential client information.
I do not currently put identifiable or potentially identifiable confidential client information into public or general-purpose AI tools. I also do not use AI to record, transcribe or analyse counselling sessions.
If this changes, I will consider the privacy, security, accuracy and professional risks before introducing the new use. I will identify an appropriate lawful basis and safeguards, provide appropriate information to clients, and update relevant agreements and this privacy statement where necessary.
Clinical and professional decisions remain my responsibility.
11. How long do I keep your information?
I do not keep personal information indefinitely. I keep it for as long as there is a reasonable need to do so, taking account of legal requirements, safeguarding, insurance, professional responsibilities and possible legal claims.
My normal retention period for counselling records is seven years after counselling ends, unless there is a good and justified reason to keep them for longer.
Other information, such as enquiries, appointment records, invoices and administrative records, may be kept for different periods because the reasons for keeping them are different.
When information is no longer needed, I will securely delete or destroy it unless there is a lawful reason to keep it
12. Your rights
Data protection law gives you a number of rights. Depending on the circumstances, you may have the right to:
• know how your personal information is being used;
• ask for a copy of your personal information;
• ask me to correct information that is inaccurate;
• ask for information to be erased in certain circumstances;
• ask me to restrict how information is used in certain circumstances;
• object to certain types of processing;
• ask for your information to be transferred to you or another organisation where the legal requirements are met; and
• withdraw your consent where I am genuinely relying on consent as the legal basis for processing.
Not every right applies to every situation.
You can contact me to make a request. You can make a request verbally or in writing, although I may ask you to put it in writing if that is reasonably necessary to deal with the request.
I will normally respond without undue delay and within one month. The law allows this period to be extended in certain circumstances, including where a request is complex or involves multiple requests.
I may need to check your identity before providing personal information, particularly where doing so could risk disclosing information to the wrong person.
13. If you have a concern or complaint
If you are unhappy about how I have handled your personal information, I would encourage you to contact me first so that I have an opportunity to understand and address your concern.
Email: contact@codacounselling.com
I will handle data protection complaints in accordance with the applicable legal requirements.
You can also complain directly to the Information Commissioner's Office (ICO), which is the UK's independent data protection regulator.
ICO website: www.ico.org.uk
Telephone: 0303 123 1113
You do not have to complain to me before contacting the ICO.
14. Changes to this statement
I will review this privacy statement when there are significant changes to my services, the organisations I use, my technology, the way I process personal information or the relevant legal requirements.
The version published on this website is the current version.
Peter Soper trading as Codacounselling
Email: contact@codacounselling.com
ICO registration: ZB635097
Last updated: 22 October 2026
Get in touch
I work weekdays and some evenings from my private practice room in the Chislehurst location.
Please feel free to contact me for an in initial chat and I will do my absolute best to help – and if for any reason I am unable to I will help you find somebody who can.
Thanks for visiting and I look forward to your contact.
Best wishes, Pete
Location
I am located in Merlewood Drive, Chislehurst, UK
BR7 5LQ
Introduction
In this video, I introduce you to my counselling and coaching services, explaining how it works and the benefits it offers.
Working together for a better future...!
powered by WebHealer | Admin