Looking after your information with care

I am Leanne Marley, trading as Leanne Marley Counselling. I am the data controller for personal information processed in connection with my counselling practice. This means I am responsible for deciding how and why your information is used and for looking after it appropriately.

Face to face counselling is offered at The Chakra Room, Shoemakers Court, 13 Bolton Street, Ramsbottom, Bury, BL0 9FZ. Online counselling is available across the United Kingdom.

I am registered with the Information Commissioner's Office (ICO) as a data controller.

ICO registration number: ZC212385

If you would like to contact me about your privacy or the way your information is handled, you can email hello@leannemarleycounselling.co.uk or use the contact page on this website.

The information I collect will depend on how you are in contact with me.

Website enquiries

If you use the website contact form, I will receive the information you choose to provide. This will usually include your:

• name;
• email address;
• telephone number, if you choose to provide it;
• preferred way of working, whether face to face, online or not sure yet; and
• message.

You do not need to share anything you are not ready to share. A short message is enough to begin.

Consultation and counselling

If we arrange an initial consultation or decide to begin counselling together, I may also collect and hold:

• Contact and emergency contact details
• Appointment times, attendance and cancellation information
• Brief clinical records and session notes relevant to our work
• Information you choose to share about your experiences, wellbeing and circumstances
• Payment and invoice records, such as amounts and dates
• Emails, messages or forms relating to our counselling arrangement.

Some of the information you share may be classed as special category data under UK GDPR. This can include information about your physical or mental health and other aspects of your personal life you bring to counselling. This information is given additional protection under data protection law.

Booking a consultation

If you choose to book a free initial consultation through the Calendly booking option on the website, Calendly will collect the information needed to arrange the call, including your name, email address, telephone number and chosen appointment time.

Calendly will also process limited technical information needed to provide its booking service securely.

Website information

The website hosting platform may process limited technical information needed to provide and protect the website, such as IP address, browser information and basic request logs.

The website will also use Umami, a lightweight, privacy focused analytics tool. More information about this is provided in the Website Analytics section below.

I will not use behavioural advertising or remarketing tools on this website.

Under Article 6 of UK GDPR, I need a lawful basis for processing your personal information. The lawful basis I rely on will depend on why the information is being used. Additional protections apply where information is classed as special category data.

Personal data

Depending on the circumstances, I may rely on:

• Contract
  If you enquire about counselling, arrange a consultation or begin counselling with me, I may need to process information in order to take steps at your request before entering into a counselling agreement and to provide counselling once we have agreed to work together.
• Legitimate interests
  I may process or retain information where there is a legitimate professional or business reason for doing so, provided this does not unfairly override your privacy. This may include keeping appropriate records for professional, ethical, insurance or legal purposes and maintaining the security and effective operation of the website.
• Legal obligation
  There may be circumstances where I am required by law to keep or disclose particular information.
• Vital interests
  In rare circumstances, information may need to be used where this is necessary to protect someone's life or safety.

Special category data

Some of the information you choose to share with me may be classed as special category data under UK GDPR. This can include information about your physical or mental health and other sensitive aspects of your personal life. This information is given additional protection under data protection law.

Where special category information is processed as part of providing counselling, I will generally rely on Article 9(2)(h) of UK GDPR, relating to the provision of health or social care or treatment, together with the relevant provisions of the Data Protection Act 2018. This information will be handled in accordance with my professional duty of confidentiality.

I will also have an appropriate lawful basis under Article 6 of UK GDPR. Where a different lawful basis or special category condition is required for a particular purpose, I will ensure that the appropriate requirements are met.

I will only use personal information where there is a clear reason for doing so. This may include:

• responding to your enquiry;
• arranging an initial consultation;
• providing counselling;
• keeping appropriate clinical and administrative records;
• arranging, confirming, changing or cancelling appointments;
• communicating with you about our work together;
• processing payments and maintaining financial records;
• meeting my professional, ethical, legal and insurance responsibilities; and
• keeping the website and practice systems secure and working appropriately.

I will not sell your personal information.

Information you share in connection with counselling will not be used to create marketing or advertising profiles about you.

I will not use automated decision making or profiling that produces legal or similarly significant effects about you.

What you share in counselling will be treated as confidential. Having a private space where you can speak openly is an important part of the counselling relationship.

As part of ethical counselling practice, I will discuss my work with a clinical supervisor. Supervision is confidential and forms an important part of maintaining safe and ethical practice. Wherever possible, identifying information will not be shared.

There are some limits to confidentiality. There may be circumstances where I need to share information because I am seriously concerned about your safety or someone else's safety, or because disclosure is required by law.

Wherever possible, I will talk with you first.

We will discuss confidentiality and its boundaries at the beginning of our work together, and you are welcome to ask questions about this at any point.

I will only share personal information where it is necessary to provide or manage the service, meet a legal or professional responsibility, or respond to a serious concern about safety.

Where another organisation processes information on my behalf, I will take reasonable steps to use reputable providers and appropriate data protection arrangements.

Services used by Leanne Marley Counselling

Website hosting

This website is hosted using Microsoft Azure Static Web Apps. Microsoft may process technical information needed to provide and protect the website.

Website enquiries and email

Information submitted through the website enquiry form is processed by an Azure Function and sent using Amazon Simple Email Service (Amazon SES). This enables your enquiry to reach my practice email account and a confirmation to be sent to you.

My day to day practice email is provided through Google Workspace. Amazon SES is used for these website transactional messages. Amazon’s privacy information can be found on the AWS website.

Appointment booking

If you choose the booking option on the contact page, Calendly will load within the website. Calendly will process the information needed to arrange your free 15 minute initial consultation.

Calendly may also use cookies or similar technologies required to provide its booking service. Calendly only loads if you choose the booking option. Simply visiting the contact page or sending an enquiry does not load Calendly. Calendly’s privacy information is available on the Calendly website.

Online counselling

Online counselling will be provided using Zoom. Zoom will process the technical information needed to connect the online session. Zoom’s privacy information is available on the Zoom website.

Counselling sessions will not be recorded.

If you are attending online counselling, I will also encourage you to consider your privacy at your end, such as choosing a private space and using headphones if this feels helpful.

Payment processing

Card payments are processed securely through SumUp, a third-party payment provider.

SumUp processes the payment and transaction information necessary to complete card payments. I do not enter clients' names or contact details when taking card payments, and I do not collect or store their full card details.

I retain appropriate payment records for accounting and legal purposes.

Further information is available in SumUp's Privacy Policy.

Website analytics

The website will use Umami to provide limited information about how the website is being used. It will not receive the contents of your enquiry, Calendly booking or counselling sessions. More information is provided in the Website Analytics section below.

Professional advisers, insurers and regulators

Information may occasionally need to be shared with organisations such as my professional indemnity insurer, legal adviser, HMRC, the ICO or BACP where there is a legitimate or legal reason to do so.

If I introduce a counselling case management system in the future, this privacy notice will be updated before client records are transferred to it.

Some of the services used by Leanne Marley Counselling may process or store information outside the United Kingdom.

Where this happens, I will take reasonable steps to ensure that appropriate safeguards required by UK data protection law are in place.

Calendly states that booking information may be processed in the United States using contractual safeguards.

If the version of Umami used for the website involves information being processed outside the United Kingdom, the appropriate safeguards and arrangements will be kept under review.

I will only keep personal information for as long as it is needed for the reason it was collected and to meet relevant professional, ethical, insurance, legal and financial responsibilities.

My usual retention periods will be:

Enquiries that do not proceed

Usually deleted or securely destroyed within 12 months of our last contact, unless there is a clear reason to retain something for longer or you ask me to delete it sooner and I am able to do so.

Counselling records

Usually retained for 5 years after our work together ends, after which they will be securely destroyed.

Financial records

Kept for the period required by tax and accounting rules.

Booking and email correspondence

Kept while relevant to our work and then deleted or retained with the relevant client record in line with the periods above.

If you would like me to consider deleting information sooner, you can ask me. There may be circumstances where I am unable to delete everything immediately because I have a professional or legal reason to retain it. If that applies, I will explain why.

I will take appropriate steps to protect personal information from loss, misuse, unauthorised access or disclosure.

These measures will include, where appropriate:

• password protection and device security;
• limiting access to client information;
• using reputable service providers with appropriate security arrangements;
• securely storing any paper records;
• keeping client information separate from unnecessary identifying information where appropriate
• taking care when communicating sensitive information electronically.

Although reasonable steps will be taken to protect your information, no method of electronic transmission or storage can be guaranteed to be completely risk free.

If a personal data breach occurs, I will assess it and follow the reporting and notification requirements that apply under UK data protection law and notify the ICO.

Under UK data protection law, you have a number of rights in relation to your personal information. Depending on the circumstances, these can include the right to:

• know how your information is being used
• ask for a copy of the information I hold about you
• ask for inaccurate information to be corrected
• ask for information to be erased in certain circumstances
• ask for the use of your information to be restricted in certain circumstances
• object to certain types of processing
• receive certain information in a portable form where applicable
• withdraw consent where processing is based on your consent (this does not affect processing already carried out).

These rights are not absolute and different rules may apply depending on the circumstances. If I cannot fully meet a request, I will explain why.

If you make a request relating to your information, I will respond in accordance with the timescales required by UK data protection law. You can find more information about your rights on the ICO website ico.org.uk/for-the-public.

If you have any concerns about how your personal information has been handled, you are welcome to contact me. I will take your concerns seriously and will try to resolve them with you where possible.

You also have the right to make a complaint to the Information Commissioner's Office (ICO).

ICO helpline: 0303 123 1113

Information Commissioner's Office complaints information

If your concern relates to my professional counselling practice more broadly, you can also contact the British Association for Counselling and Psychotherapy (BACP) through its complaints process BACP Complaints.

This website is hosted using Microsoft Azure Static Web Apps.

The website uses limited, privacy-focused analytics through Umami Cloud to help me understand how the website is being found and which pages are useful. Umami Cloud is configured to process the analytics information in its European Union region. Analytics information is retained for up to two years and then deleted in accordance with the configured retention period.

The analytics will not be used for behavioural advertising, remarketing, advertising profiles or tracking visitors across other websites.

The website and its hosting services may also use technologies necessary to provide and protect the website.

If you choose Book a consultation on the contact page, Calendly’s booking calendar will load. Calendly may use cookies or similar technologies required to provide its booking service.

Calendly does not load simply because you visit the website or submit an enquiry form. It only loads when you choose the booking option.

If you submit an enquiry form, the information you enter will be processed so that your enquiry can reach me. You only need to share what you feel comfortable putting in writing.

The website uses Umami Cloud, a lightweight, privacy-focused analytics service provided by Umami Software, Inc. Umami processes analytics information on my behalf as a service provider.

The purpose of using analytics is simple: to help me understand whether people are finding the website, which pages are being visited and whether practical information, such as the contact and fees pages, is useful.

Umami Cloud is configured to process analytics information in its European Union region. Analytics information is retained for up to two years and is then deleted in accordance with the configured retention period.

It will not be used to identify you, build an advertising profile about you or follow you across other websites.

Information Umami will collect

The information collected may include:

• the page visited;
• general referral information, such as whether a visitor arrived through a search engine;
• browser type;
• operating system;
• device type, such as phone or computer; and
• the country from which the website is visited, estimated using the IP address.

The information will be used in aggregate to understand how the website is being used. Umami states that its standard tracking anonymises the information it collects, does not store IP addresses as identifiers and does not use tracking cookies to follow individual visitors across websites.

What it will not collect

Umami will not receive:

• your name;
• your email address;
• your telephone number;
• the contents of your enquiry;
• information you enter into Calendly;
• anything you share during counselling; or
• information for advertising or remarketing profiles.

Viewing the contact page, sending an enquiry or booking a consultation will therefore not send the content of those actions to Umami.

The analytics information will only be used to understand and improve the website. No special category counselling information will be deliberately entered into Umami.

Umami Software, Inc. acts as a processor or service provider for analytics information processed through Umami Cloud. Its data-processing arrangements may permit certain processing by Umami or its service providers outside the United Kingdom where appropriate safeguards are used. Further information is available in Umami’s data-processing agreement and subprocessor information.

If the way analytics is used changes in the future, this notice will be updated before any new processing begins.

I may update this privacy notice from time to time if something about the practice changes, if I introduce a new service or system, or if legal or professional guidance changes.

The most recent version will always be available on this page and the date at the top will show when it was last updated.

If a change affects the way existing personal information is used, I will provide information about that change where required before the new use begins. The ICO specifically says privacy information should be reviewed and updated and that people should be informed about new uses before processing begins.

If you have a question about this notice or about how your personal information will be handled, please contact me.

Leanne Marley Counselling
Address: The Chakra Room, Shoemakers Court, 13 Bolton Street, Ramsbottom, Bury, BL0 9FZ
Email: hello@leannemarleycounselling.co.uk
Telephone: 07523 835479