Privacy Notice

How Perspective Practice uses and protects your personal information

1. Who I am
Perspective Practice is the trading name used by Nicola (Nicki) Wakefield, a sole trader providing counselling, coaching and related services. I am the data controller for the personal information I use in running the practice.
You can contact me at:

• Email: nicki@perspectivepractice.co.uk

• ICO registration number: ZC225600

I am not required to appoint a Data Protection Officer. Questions about your information or this notice should be sent to me using the contact details above.

2. What information I collect
The information I collect depends on your contact with the practice. It may include:

• your name, contact details and communication preferences;

• information you provide in an enquiry, introductory call, Client Details Form or optional pre-assessment. The website enquiry form asks you not to include highly sensitive or confidential information, although information you choose to provide may still include sensitive personal information;

• date of birth, emergency contact and GP or other professional details where collected for the service;

• information about your physical or mental health, wellbeing, personal circumstances, relationships, history, risk or support needs where relevant to the work;

• appointment, attendance and session information;

• notes and records relating to our work together;

• relevant emails, texts and other practice communications;

• information used for professional supervision where relevant, with identifying information minimised wherever practicable;

• payment and accounting information; and

• limited information held for the Clinical Will arrangements described below.

Some of this is special category information under data protection law, particularly health information and information that may reveal matters such as racial or ethnic origin, religion or beliefs, or sex life or sexual orientation. I only collect and use sensitive information where it is relevant and proportionate.

3. Where information comes from
Most information comes directly from you. I may also receive relevant information from another professional or service where you have agreed to this, or exceptionally where information is lawfully shared without your agreement. If I receive personal information about you from another source, I will handle it in accordance with this notice and provide any additional privacy information required by law.

4. Why I use your information and my lawful bases
Enquiries, arranging and providing the service
I use personal information to respond to enquiries, consider whether I can offer an appropriate service, arrange appointments, provide counselling/coaching, carry out ongoing assessment, communicate with you and manage the therapeutic or coaching relationship.

My main Article 6 lawful basis is contract: processing is necessary to take steps at your request before entering into an agreement and to provide the service once we are working together. Where special category information is necessary for counselling or related therapeutic work, I principally rely on the health or social care condition in Article 9(2)(h) of the UK GDPR together with the relevant condition in the Data Protection Act 2018 and my professional duty of confidentiality.

Supervision and professional standards
Clinical supervision is an integral part of safe professional practice. I may discuss client work in individual or group supervision. I minimise identifying information wherever practicable and share only what is reasonably necessary. The lawful bases are those supporting the provision of the professional service, including contract and, for relevant special category information, the health or social care condition.

Safeguarding and serious risk
Most discussion of risk, including suicidal thoughts or self-harm, remains part of ordinary confidential therapeutic work and does not automatically lead to information being shared.

In exceptional circumstances I may need to use or share information to safeguard a child or an adult who meets the relevant legal safeguarding criteria, or where another legal basis for disclosure applies. Depending on the circumstances, I may rely on a recognised legitimate interest for safeguarding, a legal obligation, or the narrow vital-interests basis. For special category information, the relevant substantial-public-interest safeguarding condition, health/social-care condition, legal-claims condition or vital-interests condition may apply. I will normally involve you in decisions about sharing information where it is safe and appropriate to do so, and will share only what is necessary and proportionate.

After the work ends
I normally retain appropriate client records for seven years after our work ends for professional, insurance, complaints and possible legal-claims purposes. The principal Article 6 basis for this post-service retention is legitimate interests. Where retained records contain special category information and retention is necessary in connection with potential legal rights or claims, Article 9(2)(f) may apply.

Payments, accounts and tax
I use the minimum information necessary to administer fees, payments, refunds, accounting and tax. The lawful bases are contract for payment administration and legal obligation where records are required for tax or accounting purposes. I keep clinical content out of financial records.

Clinical Will
If I become seriously ill, incapacitated or die and cannot contact current clients myself, a nominated professional colleague may access a restricted Clinical Will folder. The only client-identifying document available to them is a password-protected Clinical Will Client Register containing the minimum information needed to identify and contact current clients, understand their usual session pattern and current fee, and manage the immediate interruption or ending of the work.

My executor does not have routine access to my clinical notes, Client Details Forms, process notes, supervision records or practice calendar. They are bound by confidentiality. I rely on legitimate interests for the proportionate continuity and closure arrangements and, where sensitive information must be processed as part of that professional activity, the relevant special-category condition will be applied.

5. Confidentiality and when information may be shared
Counselling and coaching information is treated as confidential. I may share personal information only where there is an appropriate reason and basis to do so. This may include:

• professional supervision, using the minimum identifying information reasonably necessary;

• a GP, psychiatrist, Community Psychiatric Nurse (CPN) or another professional where we have specifically discussed and agreed the contact and what is to be shared;

• safeguarding, emergency or other exceptional disclosures where sharing is necessary and lawful;

• my professional insurer, legal adviser or professional body where necessary in relation to a complaint, claim, legal right or professional obligation;

• my nominated Clinical Will executor if the Clinical Will is activated; and

• service providers that process information on my behalf, as described below.

6. Systems and service providers
I use third-party services to operate the practice. These include Microsoft 365 for practice email, forms, files and Microsoft Teams; Wix for the website and website enquiries; and banking/payment services for financial transactions. Other suppliers may be added where needed, but I will consider their privacy and security arrangements before using them for client information.
 

These organisations may act as data processors or, for some activities, as separate controllers. They receive only the information needed for the relevant service. When you use the website enquiry form, the information you submit is stored by Wix as a form submission and a separate Wix Contact record, and a notification is sent to my Perspective Practice email account. Wix is not used as my long-term client record. Once I have dealt with the enquiry and transferred any information that needs to be retained to the appropriate practice record, I delete the Wix form submission and the associated Wix Contact record. Some service providers may process personal information outside the UK. Where this happens, appropriate arrangements are used to protect the information in accordance with UK data protection law.

7. How I store and protect information
Practice information is stored primarily within a password-protected and access-controlled Microsoft 365 environment. Identifying/contact information, clinical records, supervision material and financial records are separated where practicable. I use appropriate security measures to protect practice information, including password protection, access controls and multi-factor authentication where available.

The Clinical Will folder is separately restricted to me and my named executor. The Clinical Will Client Register is additionally password protected, with its password supplied separately to the executor.

I do not use WhatsApp for practice contact. I do not put identifiable or client-specific confidential clinical information into generative AI systems.

8. How long I keep information
I keep personal information only for as long as there is a justified need.

• Clinical/client records: my working retention period is seven years after the last session or end of the work, subject to any specific legal, insurance or professional reason requiring a different period.

• Clinical Will Client Register: current-client contact information is retained only while needed for Clinical Will purposes. When work ends, the end date and retention/destruction date are recorded and contact information and other Clinical-Will-only details are removed.

• Financial and tax records: retained for the period required by applicable tax/accounting law.

• Complaints, insurance or legal matters: relevant information may be retained for as long as reasonably necessary for the matter and any applicable legal or insurance requirement.

• Website enquiry form records held in Wix: once I have dealt with the enquiry and transferred any information that needs to be retained to the appropriate practice record, I delete the Wix form submission and the associated Wix Contact record.

• Enquiries where counselling/coaching does not proceed: relevant enquiry correspondence retained in my Perspective Practice email account is normally deleted automatically after approximately six months, unless there is a specific reason to retain particular information for longer.

When a retention period ends, I securely delete or destroy the information unless there is a documented lawful reason to retain it longer.

9. Your data protection rights
Depending on the circumstances and the lawful basis being used, you may have rights to:

• ask for access to the personal information I hold about you;

• ask me to correct inaccurate or incomplete information;

• ask for information to be erased in certain circumstances;

• ask me to restrict how information is used in certain circumstances;

• object to processing based on legitimate interests in certain circumstances; and

• receive certain information you provided to me in a portable format where the legal conditions for data portability apply.
   

These rights are not absolute. For example, I may need to retain some information despite an erasure request where there is a lawful reason to do so. I will explain if a requested right does not apply in full.

Your right to object: where I rely on legitimate interests, you have the right to object to that processing. I will consider your circumstances and stop the processing unless I have a lawful reason to continue.

I do not make decisions about clients based solely on automated processing that produce legal or similarly significant effects.

10. Complaints about how I use your information
If you have a concern or complaint about how I have used your personal information, please contact me at nicki@perspectivepractice.co.uk. You do not have to use any particular form or wording.

I will acknowledge a data protection complaint within 30 days of receiving it. I will investigate it appropriately, keep you informed where necessary, and tell you the outcome without undue delay.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator. You can do this at any point, although the ICO generally recommends giving the organisation an opportunity to resolve the issue first.

Information Commissioner's Office: ico.org.uk | Telephone: 0303 123 1113

11. Providing information
Some information is needed if I am to consider or provide counselling/coaching and manage the practical arrangements. You do not have to provide information that is not necessary or that I have described as optional. If essential information is not provided, I may be unable to offer or safely continue the service. We can discuss this if you are unsure why information is being requested.

12. Changes to this notice
I review this Privacy Notice at least annually and when there is a material change to the services, systems, data handling or law. If I make a significant change affecting how I use existing client information, I will bring it to the attention of affected clients where required.
Last updated September 2026