1. Introduction
Your privacy is very important to me, and you can be confident that your personal information will be kept safe and secure and used for the purposes it was given.
I adhere to current data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR).
This privacy notice tells you what I will do with your personal information from the first point of contact through to the end of our work together. It explains:
Why I am able to process your information, and for what purposes
What information I collect
Whether you have to provide it to me
How long I store it for
Who I share it with (if anyone)
Whether I intend to transfer it to another country
Whether I do any automated decision‑making or profiling
Your data protection rights
If you have any questions about this notice or how I handle your data, you can contact me using the details below.
2. Data controller details
The term “data controller” describes the person or organisation that collects and is responsible for personal data. In this instance, the data controller is:
Name: Relating Dots Limited
Address: Eastgate House, 121-131 Eastgate Street, Gloucester, GL1 1PX
Telephone: 07922760192
Email: [email protected]
I am registered with the Information Commissioner’s Office (ICO). My registration number is: ZC078265.
3. What information do I collect and why
Initial contact
When you contact me (via my website, email, phone, text, social media or through a third‑party referrer), I may collect:
Your name
Your contact details (email address, phone number, postal address)
How you heard about my service
Basic information about your availability, preferred location/online work
Brief information about what you are seeking help with
Any relevant accessibility needs
Referrer details where applicable (e.g. GP or organisation)
I use this information to respond to your enquiry, arrange an initial appointment and determine whether my service is likely to be suitable for you.
If you decide not to proceed, I will delete your personal information within one month of our last contact, unless we agree on a different timescale. If you would like me to delete this information sooner, please let me know.
While you are in therapy
If we agree to work together, I will collect and process additional information, including:
Your full name and contact details
Date of birth
GP name and contact details and/or other relevant health professionals
Emergency contact details
Relevant medical information and prescribed medication you choose to share
Background information and personal history you choose to share
Session notes (brief factual notes of themes and issues discussed)
Administrative information such as invoices, payment records or funding details
Some of this information will be “special category” data (for example, your mental and physical health, and possibly your race, ethnicity, religion, sexuality or other protected characteristics if you choose to share them).
I use this information to provide counselling safely and professionally, to manage our therapeutic relationship and to meet legal, regulatory and insurance requirements.
After therapy ends
Once our work together has ended, I will retain your records (including contact details and session notes) for up to seven years from the date of our last contact. This is to:
Comply with professional, legal and insurance obligations
Allow me to respond to any queries, complaints or legal claims
After this period, your records will be securely destroyed. If you would like me to delete your information sooner, please let me know; in some circumstances, I may need to retain certain information to meet my legal or insurance obligations.
4. Lawful bases for processing your information
Data protection law requires me to identify the lawful bases for my use of your personal data.
Personal data (Article 6 UK GDPR)
To respond to enquiries and provide counselling
When you contact me and/or enter into a counselling agreement with me, I rely on the lawful basis of contract (Article 6(1)(b)) because processing your personal data is necessary to take steps at your request before entering into a contract and to perform the counselling contract.
To retain records after therapy has ended
When I retain your records for up to seven years after we finish working together, I rely on legitimate interests (Article 6(1)(f)). My legitimate interests include maintaining professional records for legal, regulatory, and insurance purposes, as well as responding to queries or complaints.
Optional communications and testimonials
Where I wish to send you optional information (for example, newsletters or event updates) or use a testimonial that identifies you, I will ask for your consent (Article 6(1)(a)). You can withdraw this consent at any time.
Special category data (Article 9 UK GDPR)
Some of the information I collect is special category data (for example, your health information). The lawful basis I rely on to process this data is:
Provision of health treatment (Article 9(2)(h)): processing is necessary for the provision of health care or treatment (in this case, counselling) and for the management of health care systems and services.
This is in the context of a service contract between you and a health professional (me).
5. How I store your information and for how long
I take the security of your data very seriously and use appropriate technical and organisational measures to protect it.
Paper records (if used, e.g. signed contracts or handwritten notes) are stored in a locked filing cabinet in a secure location.
Electronic records (such as typed notes and contact details) are stored on a password‑protected and secure practice‑management system.
Mobile devices used to access your information are protected with passwords/biometric locks and, where possible, encryption.
I regularly update passwords and use reputable security software.
I keep your records for up to seven years after our last contact, unless I am required by law or my insurer to retain them for longer. After that time, I securely delete digital records and shred or otherwise securely destroy paper records.
Email and text messages are kept only as long as necessary to manage our appointments and communication. Routine messages are deleted within three months unless I need to retain relevant information in your clinical record, in which case it is transferred to my secure record system, and the original message is deleted.
6. Confidentiality and its limits
Everything you discuss with me is treated as confidential. I will not normally share your personal information with anyone else. There are, however, some exceptional circumstances when I may need to break confidentiality:
Where I believe there is a serious risk of harm to you or to someone else
Where I am required to do so by law (for example, information about certain serious crimes, terrorism or money laundering)
Where information is requested by a court order
Where there are safeguarding concerns relating to a child or vulnerable adult
Wherever possible, I will discuss any proposed disclosure with you before sharing information, unless doing so would increase the risk of harm or is not legally possible.
I also discuss my work with a clinical supervisor as part of good and ethical practice. I do not use identifying details in supervision wherever possible, and my supervisor is also bound by a duty of confidentiality.
7. Sharing your information with third parties
I sometimes need to share personal data with third parties to help me deliver my service or meet my professional obligations. These may include:
A therapeutic executor who would be given access to your contact details and relevant records in the event of my incapacity or death, so that you can be informed and your records managed appropriately.
IT and cloud‑service providers, such as Konfidens, Course Creator 360, and Bluehost, who store or process data on my behalf.
Professional advisers, such as my accountant, insurance provider or legal adviser, where access to limited information may be necessary.
Other health or support services, where we agree that a referral or liaison would be beneficial to you (for example, contacting your GP or another practitioner).
In all such cases, I share only the minimum information necessary and only for the specific purpose. Where I use third‑party service providers to process data on my behalf, I ensure that appropriate data‑processing agreements are in place and that they are committed to keeping your information secure and confidential.
I will not sell or share your information for marketing purposes.
Referrals and multi‑agency work
If, during our work, we agree that it would be helpful for you to receive support from another organisation, I may share relevant information with that organisation to facilitate a referral. This will always be done with your knowledge and consent, unless there is a serious and immediate risk that requires urgent action.
8. Case studies, training and marketing
On occasion, I may use aspects of my clinical work in:
Anonymous case studies for training, supervision or professional development
Reports or information provided to funders or commissioning organisations
Marketing materials or presentations
Any case material used in this way is normally anonymised so that the individual cannot be identified. If there is any realistic possibility that you could be identified from a case example, I will seek your explicit, written consent before using it.
Clients may also be invited to provide testimonials about their experience of working with me. Testimonials will only be used with your permission. You may choose to remain anonymous in any published testimonial, and you can withdraw your permission for future use at any time.
9. Visitors to my website
My website is hosted by Bluehost. When someone visits my website, standard internet log information and visitor behaviour patterns may be collected (for example, to see how many people visit different parts of the site). This may be done using a third‑party service such as Google Analytics or similar tools.
This information is processed in a way that does not identify individual visitors to me personally. I do not attempt to identify those visiting the site.
If you fill out a contact form on my website, the data you provide is sent to me via Course Creator 360 and may be temporarily stored by the web host. I use this information only to respond to your enquiry.
Links to other websites
My website may contain links to other websites. This privacy notice applies only to my website, so if you follow a link to another site, you should read that site's privacy policy.
10. International transfers
Some of the third‑party services I use (for example, cloud storage or email providers) may store or process data outside the UK. Where this is the case, I only use providers that implement appropriate safeguards, such as adequacy regulations or standard contractual clauses, to protect your information in line with UK data protection law.
11. Your rights
You have a number of rights in relation to your personal information. You can:
Ask for a copy of the information I hold about you
Ask me to correct any information that is inaccurate or incomplete
Ask me to delete your information in certain circumstances
Ask me to restrict how I use your information in certain circumstances
Object to me using your information in certain circumstances
Ask me to transfer your information to another provider in certain circumstances
There may be legal or professional reasons why I cannot fully comply with some requests (for example, when I need to retain records to comply with my legal or insurance obligations). If this is the case, I will explain this to you.
To make a request, please contact me in writing using the contact details in section 2.
You can read more about your rights at the ICO’s website: https://ico.org.uk/your-data-matters/
12. Complaints
If you have any concerns about how I handle your personal data, please contact me in the first instance so that I can try to resolve the issue.
If you remain unhappy, you can make a complaint to the Information Commissioner’s Office (ICO), which is the UK’s independent regulator for data protection:
Website: https://ico.org.uk/make-a-complaint/
Telephone: 0303 123 1113
13. Updates to this privacy notice
I may update this privacy notice from time to time to reflect changes in the law or in how I work. The most recent version will always be available on my website and can be provided on request in paper or alternative formats.
Updated 22nd January 2026.
© 2026 Nicholas Ferguson. All Rights Reserved. Privacy Policy
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