The Olive Branch Counselling Service Privacy Statement

The Olive Branch Counselling Service is committed to protecting your personal information, upholding confidentiality, and processing data lawfully, fairly, transparently and securely. This privacy statement explains how we collect, use, store and share personal data, the legal bases we rely upon, and your rights under UK data protection law.

This statement should be read alongside our Data Protection Policy, counselling Working Agreement, and Safeguarding Policy.

  1. Who we are
    The Olive Branch Counselling Service Ltd is the data controller for the personal information we collect and use.
    Registered office:14 St Clement Street, Winchester SO23 9HH.
    We are registered with the Information Commissioner’s Office. 
  2. What personal information we collect
    We collect information directly from you when you enquire, register, attend an assessment appointment, attend counselling sessions, or communicate with us. This includes:
  • Name, postal address, phone number and email address
  • Date of birth
  • GP surgery, health and medication information for safety and emergency purposes
  • Demographic information such as age, employment status and postcode
  • Information you provide during enquiries or assessments
  • Brief factual counselling notes that do not contain names or identifiable details
  • Records of consent, working agreements, safeguarding decisions and relevant communications

We also collect non-identifiable statistical information to help us understand who uses our service and to support funding applications.

3. Special category data
We may process health information and other special category data where necessary for counselling, safeguarding, supervision or legal duties. We rely on Article 6 lawful bases such as contract, legitimate interests and legal obligation, and Article 9 conditions including the provision of health care and explicit consent where appropriate.

4. Purposes and lawful bases for processing
We process personal data for the following purposes:

  • Providing counselling and related services
  • Contacting you about appointments
  • Assessing suitability for counselling
  • Safeguarding and emergency procedures
  • Clinical supervision and service quality
  • Administration, audit and governance
  • Producing non-identifiable statistics
  • Meeting legal and regulatory duties

Our lawful bases include contract, legitimate interests, legal obligation and explicit consent where required.

5. How we store and protect your information
All personal data is stored securely within our Microsoft SharePoint cloud system. Access is restricted to authorised counsellors, supervisors, clinical staff and administrative staff. We use appropriate technical and organisational measures to protect confidentiality, integrity and availability.

Paper records are not routinely used. Any paper documents are stored securely and shredded when no longer required. Digital records are deleted securely in line with our retention schedule.

6. Use of digital tools and AI
We may use approved digital tools to support administration or service delivery. We do not input any personal data into AI tools. Professional judgement is never delegated to AI.

7. Sharing your information
We will only share personal data where there is a clear lawful basis and the disclosure is necessary and proportionate. Wherever possible, we will involve you in the decision.

We may share information:

  • With your GP or emergency services if there is a significant risk of harm
  • With statutory agencies where required by law
  • With approved processors who provide secure digital or administrative services
  • With supervisors or clinical managers for professional oversight

We do not sell personal information.

Only the minimum necessary information is shared, using secure methods.

8. Safeguarding and emergency procedures
If a counsellor believes you or someone else may be at risk, they will follow our safeguarding policy. If working remotely, at the start of each session, counsellors confirm your location and privacy arrangements so they can respond appropriately in an emergency.

9. How long we keep your information
We keep personal data only for as long as necessary.

  • Counselling records are kept for one year after counselling ends, then securely deleted
  • Records for clients who enquire or attend assessment but do not begin counselling are deleted after three months
  • Non-identifiable statistical information may be retained for longer for reporting and funding purposes

Any deviation from our retention schedule is documented with reasons.

10. Your rights
You have rights under UK GDPR, including:

  • The right to be informed
  • The right of access to your personal data
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to object
  • The right to data portability
  • Rights relating to automated decision-making

You may request a copy of your personal data at any time. Requests can be made verbally or in writing. We may ask for proof of identity and will respond within one month.

If we are unable to fulfil a request, we will explain the legal reasons clearly.

11. Cookies and electronic communications
Visitors to our website can choose whether cookies are stored on their device. We maintain an email list for service updates and fundraising events. We will only send electronic communications where you have subscribed or where you are an existing subscriber with an option to unsubscribe in every message.

12. Complaints
If you have concerns about how your data has been handled, you can contact our Data Protection Lead via Enquiries@theolivebranch.org.uk. You also have the right to complain to the Information Commissioner’s Office at www.ico.org.uk.

13. Updates to this statement
This privacy statement will be reviewed annually or when required by changes in law, guidance or organisational practice.

The Olive Branch Counselling Service Ltd.