Privacy Policy

This Privacy Notice explains how Mo Counselling collects, uses, stores, and protects your personal information, in accordance with UK GDPR (General Data Protection Regulation) requirements. This notice applies to all personal data we process about you, whether collected:

During in-person therapy sessions
Through our website and online booking system
Via email, telephone, or other communications
Through any paper forms or documents you complete

Content

Contact details
What information we collect, use, and why
Lawful bases and data protection rights
Where we get personal information from
How long we keep information
Who we share information with
Duty of confidentiality
Sharing information outside the UK
How to complain

Contact details

Email

info@mocounselling.com

What information we collect, use, and why

We collect or use the following information to provide patient care and services:

Name, address and contact details
Gender
Pronoun preferences
Date of birth
Next of Kin details including any support networks
Emergency contact details
Health information (including medical conditions, allergies, medical requirements and medical history)
Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)
Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
Payment details (including card or bank information for transfers and direct debits)
Information about income and financial needs for funding or personal budget support

We collect or use the following information to provide patient care and services:

Racial or ethnic origin
Religious or philosophical beliefs
Health information
Sexual orientation information

We collect or use the following information for safeguarding or public protection reasons:

Name, address and contact details
Emergency contact details
Health information (including medical conditions, allergies, medical requirements and medical history)
Information about care needs (including disabilities, home conditions, dietary requirements and general care provisions)
Relevant information from previous investigations
Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)

We also collect the following information for safeguarding or public protection reasons:

Racial or ethnic origin
Religious or philosophical beliefs
Health information
Sexual orientation information

We collect or use the following personal information for patient app or portal functionality:

Names and contact details
Addresses
Payment details
Account information, including registration details
Information used for security purposes
Date of Birth

We also collect the following information for patient app or portal functionality:

Health information

We collect or use the following personal information to comply with legal requirements:

Name
Contact information
Safeguarding information

We also collect the following information to comply with legal requirements:

Racial or ethnic origin
Religious or philosophical beliefs
Health information
Sexual orientation information

We collect or use the following personal information for dealing with queries, complaints or claims:

Names and contact details
Correspondence

Lawful bases and data protection rights

Under UK data protection law, we must have a "lawful basis" for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO's website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO's website:

Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about this right here.
Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about this right here.
Your right to erasure – You have the right to ask us to delete your personal information. Read more about this right here.
Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. Read more about this right here.
Your right to object to processing – You have the right to object to the processing of your personal data. Read more about this right here.- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about this right here.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods are:

Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interest – As a therapy provider, Mo Counselling collects and uses client information to deliver effective mental health support. This includes maintaining session notes, treatment plans, and progress records, which help tailor therapy to individual needs and ensure continuity of care. The benefit of this data collection is that it allows us to provide safe, personalised, and high-quality support. We minimise risks by only collecting necessary information, keeping it secure, and ensuring confidentiality, so our clients' privacy is protected while they receive the best possible care.
Vital interests – collecting or using the information is needed when someone's physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for safeguarding or public protection reasons are:

Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- As a therapy provider, we have a duty to safeguard clients and others from harm. In rare cases where there is a serious risk to a client's safety or the safety of others, we may need to collect and share relevant personal information with appropriate authorities. The benefit of this is to prevent harm, protect vulnerable individuals, and ensure a safe environment. We only act when necessary, following strict confidentiality and legal guidelines to minimise risks while prioritising the well-being of those involved.
Vital interests – collecting or using the information is needed when someone's physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for patient app or portal functionality are:

Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legitimate interests – we're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- We use EasyPractice to manage client bookings, ensuring a smooth and efficient appointment process. Collecting personal information, such as contact details and appointment history, allows clients to schedule, reschedule, and receive reminders about their sessions. The benefit is improved accessibility, convenience, and continuity of care. This reduces missed appointments, ensures clients receive timely support, and allows for secure communication. We minimise risks by using a trusted, GDPR-compliant platform that protects client data and ensures confidentiality.

Our lawful bases for collecting or using personal information to comply with legal requirements are:

Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Legitimate interests – we're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- We collect personal information through our review and contact forms to respond to inquiries about therapy services, allow clients to share their experiences, and help potential clients get information on starting therapy. This enables us to provide clear communication, address complaints or concerns, and improve our services. Additionally, we collect personal data to protect against spam and ensure the integrity of the communication process. This helps maintain a secure and respectful environment for all users. We only collect necessary details, store them securely, and make sure that any reviews shared respect confidentiality.

Where we get personal information from

Directly from you
Regulatory authorities
Family members or carers
Other health and care providers
Social services
Charities or voluntary sector organisations
Schools, colleges, universities or other education organisations
Relevant regulatory authorities

How long we keep information

Mo Counselling retains client information for a period of 3 years after the conclusion of therapy or our last contact. This includes:

Session notes and records
Contact information
Correspondence
Financial records related to your therapy
Initial assessment information

This 3-year retention period is in line with professional guidelines and allows us to:

Provide continuity of care should you return to therapy
Comply with our professional indemnity insurance requirements
Fulfill our obligations for record-keeping as required by our professional body

After this 3-year period has elapsed, your personal information will be securely destroyed or anonymized in accordance with UK data protection regulations.

If you have any questions about our data retention policies or wish to request early deletion of your data (where legally permissible), please contact us using the details provided in this privacy notice.

Client reviews are retained for 10 years to help maintain service quality, promote our services and track long-term feedback. If you wish to request removal of a review, please contact us using the details in this notice.

Data processors

FriendlyCaptcha, Bot protection service, Germany (with EU compliance)

This data processor does the following activities for us: Helps prevent automated spam by requiring visitors' devices to solve a cryptographic challenge to ensure they are human. FriendlyCaptcha does not store personal data beyond what is necessary to verify form submissions before they're sent to us.

EasyPractice – Booking and Payment Management Software, SaaS, Denmark (EU Compliant)

This data processor does the following activities for us: Provides an online booking and payment management system for therapists and healthcare professionals. It helps streamline appointment scheduling, client management, and payment processing.

Airtable, Cloud-based data storage and management, SaaS, United States (with EU compliance)

This data processor does the following activities for us: Airtable is used to collect and store client names, emails, and reviews for our review system, helping us manage and organize feedback effectively.

Altrin Systems Technology system, IT support and infrastructure management, IT Services, UK

This data processor does the following activities for us: Altrin Systems Technology sets up and manages email systems, provides IT support, ensures secure internet access, and delivers training, ensuring the smooth operation of our IT infrastructure.

Joint controllers

AChellCompany, Technology system, IT support and infrastructure management, IT Services, UK

This joint controller does the following activities for us: AChellCompany provides web development to maintain the website, update its content, and ensure its proper functioning. As a joint controller, they may determine the purposes and means of processing personal data related to website operations.

Other health providers (eg GPs and consultants)
Organisations we need to share information with for safeguarding reasons
Emergency services
Professional advisors
Legal bodies or authorities
Relevant regulatory authorities
Organisations we're legally obliged to share personal information with
Publicly on our website, social media or other marketing and information media
Other relevant third parties:
- Parents or legal guardians of clients under 18, where appropriate

Duty of confidentiality

We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:

you've provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
we have a legal requirement (including court orders) to collect, share or use the data;
on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.

Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.

For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Organisation name: FriendlyCaptcha

Category of recipient: Bot Protection Service

Country the personal information is sent to: Germany

How the transfer complies with UK data protection law: Germany has been granted a UK data bridge (Adequacy Regulations).

Organisation name: EasyPractice

Category of recipient: Booking Portal

Country the personal information is sent to: Denmark

How the transfer complies with UK data protection law: The country or sector has a UK data bridge (also known as Adequacy Regulations)

Organisation name: Airtable

Category of recipient: Storage Provider

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

Organisation name: Microsoft

Category of recipient: Storage

Country the personal information is sent to: United States

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we've used your data after raising a complaint with us, you can also complain to the ICO.

The ICO's address:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint/

Created: 10/02/2025

Updated: 31/03/2025