Privacy Notice
Jenette-Marie Ogborn | Space2B Counselling
Registered Member MBACP – 01015371
space2bcounselling@gmail.com | 07392 554984
ICO registration number: ZC254894 | Adults aged 18 and over
Revised draft: 2 October 2026
This notice explains how personal information is used for adult counselling, including telephone, online, in-person and Walk and Talk sessions.
Who is responsible for your information
Jenette-Marie Ogborn, trading as Space2B Counselling, is the data controller responsible for deciding how and why your personal information is used.
Email: space2bcounselling@gmail.com
Telephone: 07392 554984
ICO registration number: ZC254894
Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Information I may collect
I may collect:
Your name, preferred name and pronouns.
Your date of birth.
Your address and contact details.
Your GP details.
Emergency-contact information.
Appointment and attendance information.
Payment and financial-transaction records.
Correspondence between us.
Brief counselling and supervision notes.
Relevant background information you choose to share.
Information needed to assess suitability, risk or safeguarding concerns.
Technical or account information generated by email, telephone or video services.
Counselling may involve special-category information, including information about:
Physical or mental health.
Disability or neurodivergence.
Racial or ethnic origin.
Religious or philosophical beliefs.
Sex life or sexual orientation.
Other sensitive matters you choose to discuss.
I do not routinely collect all these categories. I only record information that is relevant and proportionate to providing the service safely and professionally.
Why I use your information
I use information to:
Respond to enquiries.
Arrange and provide counselling.
Communicate about appointments.
Assess whether the service is suitable and safe.
Maintain appropriate counselling records.
Manage fees and payments.
Make reasonable adjustments.
Respond to risk or safeguarding concerns.
Obtain professional supervision.
Respond to complaints or legal claims.
Meet legal, insurance and professional responsibilities.
Lawful bases
For ordinary personal information, the lawful bases that may apply are:
Contract – Article 6(1)(b): where information is needed to enter into or fulfil our counselling agreement.
Legal obligation – Article 6(1)(c): where a specific law requires information to be processed or disclosed.
Vital interests – Article 6(1)(d): in a serious emergency where processing is necessary to protect someone’s life.
Legitimate interests – Article 6(1)(f): for proportionate activities such as maintaining professional records, responding to complaints, establishing legal claims and protecting the safe operation of the practice.
Where legitimate interests are used, I consider whether the processing is necessary and whether your rights and interests override those interests.
For health and other special-category information needed to provide counselling, I normally rely on:
Article 9(2)(h), together with Schedule 1 paragraph 2 of the Data Protection Act 2018: processing necessary for health or social care or treatment, subject to Article 9(3) and an applicable legal duty of confidentiality. This condition is used only where its requirements are met.
Other conditions may apply in limited circumstances, including:
Article 9(2)(c): vital interests in a serious emergency where a person cannot give consent.
Article 9(2)(f): establishing, exercising or defending legal claims.
Consent will only be used as the data-protection basis where it is genuinely appropriate. Consent to participate in counselling is separate from the lawful bases used to maintain necessary professional records.
Where information comes from
Information normally comes directly from you.
In limited circumstances, information may also come from:
A parent, carer or family member.
An emergency contact.
Your GP or another professional.
A referring organisation.
Emergency or safeguarding services.
I will explain this where it is appropriate and safe to do so.
How information is stored
Information is stored using proportionate security measures, which may include:
Password-protected devices and accounts.
Multi-factor authentication where available.
Locked physical storage.
Secure deletion or confidential destruction.
Restricted access to counselling records.
Paper counselling notes are stored in a locked cabinet. Access is limited to the counsellor unless a controlled and lawful disclosure is necessary.
I do not enter identifiable client information into an artificial-intelligence system without a separate discussion, a valid lawful basis and appropriate safeguards.
Digital services
Services used by Space2B may include:
Google Gmail for email.
Microsoft Teams for video sessions.
Microsoft services for documents or storage.
Website-hosting services for enquiries.
Telephone-network providers.
Banking services for payments.
These organisations may act as data processors or independent controllers, depending on the service they provide.
Some providers may process information outside the United Kingdom. For any restricted transfer, I identify the applicable lawful mechanism, such as UK adequacy regulations or appropriate safeguards including the UK IDTA or UK Addendum, and undertake any required assessment.
Please remember that ordinary email and text messages may not provide complete confidentiality. Avoid including highly sensitive information in appointment messages unless necessary.
Sharing information
Information may be shared, where necessary and lawful, with:
My clinical supervisor.
Service providers used for email, video calls, telephone, payments, website enquiries or secure storage.
Emergency services.
Safeguarding organisations.
Your GP, emergency contact or another professional where there is an appropriate reason and lawful basis.
Professional advisers, insurers or legal representatives.
Courts, police or other organisations where disclosure is legally required or otherwise lawful and proportionate.
I do not sell your information or share it for unrelated marketing.
Retention
Adult counselling records, including relevant assessment forms, risk assessments, agreements and session notes, are normally kept for seven years after counselling ends and then securely destroyed. Records connected with a complaint, safeguarding matter, insurance notification or legal claim may need to be retained for longer where justified. Unnecessary duplicate or temporary information is securely destroyed when no longer needed.
Payment and accounting records may be kept for the period required by tax and financial-record requirements.
Your information rights
Depending on the information and lawful basis involved, you may have the right to:
Be informed about how your information is used.
Request access to your information.
Ask for inaccurate information to be corrected.
Ask for information to be deleted in certain circumstances.
Ask for processing to be restricted.
Object to processing based on legitimate interests.
Receive certain information in a portable format where the legal conditions apply.
Withdraw consent where consent is the lawful basis.
These rights are not absolute. For example, information may need to be retained where there is a legal, safeguarding, insurance or legal-claims reason.
I normally respond to an information-rights request within one month. Where the law permits an extension or pause, I will explain the reason and applicable timescale. I may need to confirm your identity before releasing information.
Privacy concerns and complaints
If you have a concern about how your information has been handled, please contact:
Email: space2bcounselling@gmail.com
Telephone: 07392 554984
You may also complain to the Information Commissioner’s Office:
Website: ico.org.uk/make-a-complaint
Telephone: 0303 123 1113
Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
