Clinical & Data Protection Policies
Henrietta Ray Counselling • Practice Policies & Privacy Notice
Practitioner: Henrietta Ray (Henrietta Ray Counselling)
Professional Body: BACP Registered Member (MBACP) | Membership No: 391113
Data Protection: UK GDPR Data Controller | ICO Registration: ZB540464
1. Clinical & Data Protection Complaints Policy
Clinical Complaints
If you have any questions or complaints about my professional conduct, I encourage you to email me or discuss it in your next session to see if we can resolve the issue. If we are unable to resolve your concern or if you prefer not to approach me directly, you may contact the BACP directly at www.bacp.co.uk and they will address your concerns through their complaints procedure detailed here: How to Complain About a BACP Member.
Legal Framework
I am currently based in the UK and work in accordance with English law. Any complaints or disputes are subject to English law.
GDPR Privacy Notice and Data Protection Policy
This notice describes what personal data we collect from you and how we store and process it as part of the counselling services provided by Henrietta Ray. In the course of our practice, we will collect, process and store personal data as a data controller.
We would like to reassure you that we adhere to all laws and procedures relating to the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018, and other applicable data privacy legislation, and will only use your personal data to provide you with the specific service or services you explicitly agree to. We are registered with the Information Commissioner’s Office (ICO) under registration reference ZB540464.
Complaints Procedures
I am committed to providing a professional, ethical, and respectful service. If you are unhappy with any aspect of our work together, I encourage you to raise your concerns. Feedback and complaints are taken seriously and will be responded to with care, transparency, and respect.
I recognise that concerns and complaints can arise when there has been a misunderstanding, disappointment, communication difficulty, or rupture in the therapeutic relationship. Wherever possible, I aim to address concerns openly and collaboratively.
You can expect your complaint to be:
- Acknowledged promptly;
- Taken seriously and not dismissed or minimised;
- Responded to respectfully and professionally;
- Handled in a timely manner;
- Considered fairly and thoughtfully;
- Addressed with clear communication about next steps and expected timeframes;
- Managed in accordance with my professional and legal obligations, including UK GDPR and data protection legislation.
Making a complaint will not affect your right to receive respectful treatment or access information about how your complaint is being handled.
How to Make a Complaint
If you have a concern or complaint (whether clinical or regarding your data protection rights), please contact me directly by email at [email protected].
Please provide as much information as you feel comfortable sharing, including:
- What happened;
- When the issue occurred;
- The impact it has had on you;
- What outcome you are seeking, if known.
You may also choose to discuss clinical concerns during a therapy session if that feels appropriate.
What Will Happen Next
Step 1: Acknowledgement
• For Clinical Complaints: I will personally acknowledge receipt of your complaint within 48 hours (excluding periods of planned leave, which will be communicated in advance where possible).
• For Data Protection Complaints: In accordance with statutory requirements, I will formally acknowledge your data concern within 30 days of receipt.
This acknowledgement will confirm receipt, outline the next steps, and provide an estimated timeframe for a full response.
Step 2: Review
I will carefully review the concerns you have raised and any relevant records or correspondence. Where appropriate, I may invite further discussion to better understand your experience and the impact of what has occurred. My aim is not simply to determine what happened, but also to understand how the situation has affected you and whether repair or resolution is possible.
Step 3: Response
I aim to provide a full written response within 14 calendar days of receiving a clinical complaint, and without undue delay for data complaints. If additional time is needed, I will inform you of the reason and provide an updated timeframe.
My response will include a summary of the concerns raised, my understanding of the issues, any findings arising from my review, actions I will take as a result, and information about further options available to you if you remain dissatisfied.
Resolution and Remedies
Depending on the nature of the complaint, possible outcomes may include an explanation or clarification, an acknowledgement of mistakes or shortcomings, an apology where appropriate, changes to policies, procedures, or practice, referral to an alternative practitioner if appropriate, or a partial or full refund of fees where I determine this to be a fair and reasonable response.
Financial compensation beyond fees already paid is not normally available through this complaints process.
Escalating a Complaint
For Clinical & Ethical Conduct Complaints
You can raise your concerns with my professional membership body. I am a registered member (MBACP) of the BACP, and my Membership Number is 391113. Please note that professional bodies have their own eligibility criteria, complaints procedures, and time limits.
For Data Protection & Privacy Complaints
You have the statutory right to escalate your complaint to the UK’s independent data regulator, the Information Commissioner’s Office (ICO). Under current regulations, you must allow me to investigate your data complaint first before escalating. You can contact them via their website at ico.org.uk/make-a-complaint or via their helpline on 0303 123 1113.
Data Protection and Confidentiality
Information provided as part of a complaint will be handled confidentially and in accordance with UK GDPR and applicable data protection legislation. Complaint records may include correspondence, notes, clinical records where relevant, and documentation relating to the investigation and outcome. Your information will be processed for the legitimate purpose of reviewing, responding to, and resolving the complaint, and for meeting professional, ethical, legal, and insurance requirements. Complaint records will be retained only for as long as necessary to fulfill these purposes and in accordance with my data retention policy. You have rights regarding your personal data, including the right to request access to information held about you, subject to any legal or professional limitations. Further information can be found in my Privacy Notice.
Commitment to Learning
Complaints can provide valuable opportunities for reflection and improvement. Where appropriate, I will use feedback and complaints to review my practice, strengthen professional standards, and improve the quality of the service I provide.
2. Privacy Notice
Henrietta Ray Counselling (“I”, “me”, “my”) is the Data Controller responsible for the personal information collected and processed as part of providing counselling services.
What Information I Collect
- Name, address, telephone number and email address
- Date of birth
- Parent/carer details (where relevant)
- GP and other relevant healthcare professional details (where relevant)
- Emergency contact details
- Information disclosed during assessments and counselling sessions
- Brief clinical notes/themes relating to our work together
- Administrative information relating to appointments, payments and correspondence
Why I Collect Your Information
- Provide counselling services
- Maintain clinical records
- Manage appointments and communications
- Meet professional, ethical and safeguarding responsibilities
- Comply with legal and regulatory requirements
Lawful Basis for Processing
Under UK GDPR, the lawful basis for processing your personal data is my legitimate interests in providing safe and effective counselling services and fulfilling my professional obligations.
Information relating to your physical or mental health is considered “special category data”. This information is processed for the provision of counselling and mental health support and in accordance with applicable UK data protection legislation.
Confidentiality and Information Sharing
Information shared within counselling sessions is treated as confidential. Information will not normally be shared with third parties without your knowledge and consent. However, confidentiality may need to be breached where:
- There are safeguarding concerns relating to an adolescent or vulnerable person
- There is a serious risk of harm to yourself or others
- Disclosure is required by law, court order, or other legal obligation
- It is necessary to prevent or detect serious crime
As part of professional practice, I may discuss aspects of my work in confidential clinical supervision. Identifying details will be minimised wherever possible, and supervisors are themselves bound by professional and confidentiality requirements.
Storage and Security
Your information is stored securely using appropriate technical and organisational measures designed to protect confidentiality and prevent unauthorised access, loss, misuse or disclosure.
Where I use third-party service providers (such as secure email, video conferencing, payment processing or practice management systems), these providers are selected carefully and are required to handle personal information securely and in accordance with data protection requirements.
Retention of Records
Personal information and counselling records are retained for seven years following the end of therapy and are then securely destroyed, unless a longer retention period is required by law, safeguarding considerations, insurance requirements or professional obligations.
Your Rights
Under UK GDPR, you have the right to request access to the personal information I hold about you, request correction of inaccurate or incomplete information, request restriction of processing in certain circumstances, or object to processing.
Please note that some rights may be limited where records are required for legal, insurance, safeguarding or professional purposes.