Privacy Policy
Who We Are
Organisation and Data Controller: DEBELL LTD (trading as DeBell Counselling). Data protection contact: Debra Bell, Registered Member MBACP 420184. Address: Cottingham, East Yorkshire (postal address available on request). Email: contact@debell.co.uk. Phone: 07867 818018. Website: www.debell.co.uk. ICO Registration Number: ZC125133.
DeBell Counselling is a private counselling practice working with adults aged 18 and over. Debra Bell works to the BACP Ethical Framework for the Counselling Professions and is bound by a professional duty of confidentiality. This policy covers counselling. It does not cover mediation or consultancy services provided by DEBELL LTD.
What Data We Collect
For clients and prospective clients we collect: contact information (name, email address, phone number, postal address), enquiry details including how you heard about us, date of birth, GP name and surgery, emergency contact details, health and mental health information shared in counselling, session notes and clinical records, appointment and booking details, payment and invoicing records, and all communications between you and Debra Bell by email, phone, text message or WhatsApp. All communications form part of your client record, whichever route is used.
If you use the contact form or booking system on our website we collect your name, email address, phone number, and the content of your message. Our website uses cookies, explained in our Cookie Policy at www.debell.co.uk. The online booking form is provided by Zanda Health, which may set its own cookies. If you subscribe to our newsletter or follow our social media pages, those platforms handle your data under their own privacy policies.
How We Use Your Data
To provide counselling services and manage the therapeutic relationship, to communicate about appointments and invoices including automatic reminders, to keep clinical records as required by professional standards, to ensure the safety of you and others including safeguarding obligations, to comply with legal and professional obligations, to process payments, and to respond to enquiries, concerns and complaints.
Legal Basis for Processing
Contract (providing counselling, arranging appointments, taking payment), legitimate interests (managing the practice, keeping clinical records, professional supervision, meeting professional body standards, responding to enquiries), legal obligation (safeguarding, disclosures required by law, keeping financial records), vital interests (where necessary to protect life), and consent (only where we ask for it specifically, for example before publishing a testimonial or entering identifiable information into an AI tool).
Special category health data is processed under Article 9(2)(h) UK GDPR and Schedule 1, Part 1, paragraph 2 of the Data Protection Act 2018. Where information is shared to protect a child or adult at risk, we rely on Schedule 1, Part 2, paragraph 18 of that Act.
Confidentiality and Who We Share Your Data With
Your data is confidential. We do not sell, rent, or share your personal data for marketing purposes. We may share in the following limited circumstances: with our clinical supervisor (Joy Wanless) in professional supervision; with your GP, emergency services or statutory authorities where there is a serious risk of harm to you or to someone else; where there is a safeguarding concern about a child or adult at risk; where required by law or court order; to prevent or help detect a serious crime; with third-party service providers including Zanda Health (practice management, records, booking, reminders and video, under a data processing agreement) and Stripe (payment processing); with our practice manager, who has limited access to the appointment calendar only and is bound by a confidentiality agreement; with a nominated professional executor who would contact you only if Debra Bell became seriously ill, unable to work or died; and with our insurer, legal advisers or BACP where needed to respond to a complaint.
Wherever possible Debra Bell will talk to you before sharing information about you. This may not be possible where it would increase the risk of harm or where the law does not allow it.
Couples Counselling
A shared record is kept for each couple. Where a partner has an individual session as part of the couples work, the note for that session is held in the shared record or under that partner's own client record. Each partner may ask for a copy of their own information. Information about the other partner will not be released without that partner's consent, unless the law requires it.
Use of Artificial Intelligence and Digital Tools
Debra Bell may use AI tools for administration, writing and professional reflection. Information is anonymised first, so nothing that could identify you is entered into an AI tool. Identifiable information would only ever be entered into an AI tool with your informed consent given in advance. You are free to say no, and it will not affect your counselling. AI is not used to make decisions about you or your therapy. We do not use automated decision-making or profiling.
Data Retention
Client records are retained for seven years following the end of therapy. Prospective client records who did not proceed are retained for six months then securely deleted. Financial records are retained for six years (HMRC requirements). Complaint records are retained for seven years after the complaint is closed. Records are then securely and permanently destroyed.
How We Store Your Data
Client records are stored using Zanda Health (GDPR-compliant, ISO 27001-certified). All data is encrypted in transit and at rest. Paper records are in a locked cabinet. Email is via a secure business account. The phone and computer used for the practice are password protected. Zanda Health hosts client records in the UK. Some providers including Stripe and Meta (WhatsApp) may process data outside the UK, protected by safeguards recognised under UK data protection law. If a data breach is likely to put your rights at risk, we will tell you promptly and report to the ICO within 72 hours where required.
Your Rights
Under UK GDPR you have the right of access, rectification, erasure, restriction, data portability, the right to object to processing based on legitimate interests, and the right to withdraw consent where it was given. Contact Debra Bell at contact@debell.co.uk to exercise any right. We will respond within one calendar month. Some rights are limited in the context of health records and we will explain any limitations.
Complaints
If you have a concern about how we handle your personal data, contact Debra Bell at contact@debell.co.uk in the first instance. Our Complaints Procedure is available at www.debell.co.uk/complaints. If not satisfied, you have the right to complain to the ICO: www.ico.org.uk | 0303 123 1113.
Changes to This Policy
This policy is reviewed annually or whenever there is a significant change. The current version is always available at www.debell.co.uk and on request by email.