Privacy Notice

Practice Name: Benjamin Vittori Counselling
Counsellor: Benjamin Vittori MBACP
Email: bvittoritherapy@gmail.com
Telephone: 07428 053 128
Privacy Notice Version: 1.0
Effective Date: 30 June 2026
Review Date: June 2027 (or sooner if legislation, professional guidance or my practice changes)

Introduction

Your privacy is important to me. This Privacy Notice explains how I collect, use, store and protect your personal information when you enquire about counselling, receive counselling from me, or contact me through my website.

I process personal information in accordance with:

  • The UK General Data Protection Regulation (UK GDPR)
  • The Data Protection Act 2018
  • Relevant guidance issued by the Information Commissioner's Office (ICO)
  • My professional responsibilities as a counsellor, including the Ethical Framework of the British Association for Counselling and Psychotherapy (BACP)

This Privacy Notice explains what information I collect, why I collect it, how it is stored, who it may be shared with, and your rights regarding your personal information. If you have any questions about this Privacy Notice or how I process your information, please contact me using the details above.

1. Who is responsible for your information?

I am the Data Controller responsible for deciding how your personal information is collected and used.

Data Controller: Benjamin Vittori
Practice: Benjamin Vittori Counselling

As an independent private counsellor, I am responsible for ensuring that your personal information is handled securely, confidentially and lawfully.

2. Who this Privacy Notice applies to

This Privacy Notice applies to adults who:

  • contact me to enquire about counselling;
  • attend counselling sessions;
  • are referred to me by another therapist or healthcare professional;
  • contact me through my website.

I provide counselling services to adults only.

3. Information I collect

The information I collect depends on our contact and therapeutic relationship.

Personal information

This may include:

  • name;
  • address;
  • telephone number;
  • email address;
  • date of birth;
  • emergency contact details (where provided by you);
  • GP details where relevant;
  • occupation;
  • payment records and invoices.

Special category information

Counselling often involves discussing sensitive personal information. This may include:

  • mental health information;
  • physical health information;
  • medical history;
  • psychiatric history;
  • medication;
  • previous counselling or therapy;
  • emotional and psychological difficulties;
  • relationships and family circumstances;
  • experiences discussed during counselling sessions;
  • racial or ethnic origin where relevant;
  • religious or philosophical beliefs where relevant;
  • sexual orientation or gender identity where relevant;
  • information relating to criminal offences or convictions where relevant to the therapeutic work and voluntarily disclosed by you.

Most information is provided directly by you.

I may also receive information from another therapist or healthcare professional where you have requested or agreed to a referral. I only collect information that is reasonably necessary to provide counselling, manage my professional practice and meet my legal, ethical and insurance obligations.

4. How I use your information

I use your personal information to:

  • respond to counselling enquiries;
  • assess whether counselling is appropriate;
  • provide counselling sessions;
  • maintain accurate clinical records;
  • communicate with you about appointments;
  • arrange and manage sessions;
  • process payments;
  • receive and make referrals where appropriate;
  • meet professional, legal and insurance requirements;
  • support safe and ethical counselling practice.

I only collect and use information that is relevant and necessary for these purposes.

5. Lawful basis for processing your information

Under Article 6 UK GDPR, I rely on one or more of the following lawful bases where applicable:

Contract

Processing is necessary to provide the counselling service you have requested.

Legitimate Interests

Processing is necessary for the safe and effective operation of my counselling practice while respecting your rights and freedoms.

Legal Obligation

Processing is necessary where I must comply with legal or regulatory requirements.

Because counselling involves processing special category personal data, including information relating to your health, I normally rely on Article 9(2)(h) UK GDPR (the provision of health or social care). Where appropriate, I may also rely on Article 9(2)(f) (the establishment, exercise or defence of legal claims) or another applicable condition under UK GDPR.

6. Confidentiality

Counselling is confidential. I respect your privacy and will not disclose information about you unless there is a lawful and necessary reason to do so.

There are limited circumstances where confidentiality may need to be broken, including:

  • where there is a risk of harm to yourself or others;
  • where safeguarding concerns arise;
  • where disclosure is required by law, including under a court order;
  • where disclosure is permitted by law, including where necessary to prevent or detect serious crime;
  • where information is discussed with my clinical supervisor as part of safe and ethical practice.

Where possible and appropriate, I will discuss any concerns with you before information is shared unless doing so would increase risk or prevent me from meeting my legal or ethical responsibilities.

7. Clinical supervision

In accordance with BACP ethical requirements, I regularly discuss my counselling work with qualified clinical supervisors. Supervision supports safe, ethical and effective practice. Wherever possible, information discussed during supervision is anonymised or shared using the minimum identifiable information necessary.

My clinical supervisors are also bound by professional confidentiality obligations.

8. Sharing your information

Your information will never be sold or used for marketing purposes. I will only share your personal information where it is necessary or lawful to do so.

This may include:

  • clinical supervisors;
  • healthcare professionals involved in your care where appropriate;
  • another therapist involved in a referral;
  • HM Revenue & Customs where required by law;
  • professional advisers or insurers where necessary;
  • trusted service providers that support my practice;
  • in the case of risk of harm to yourself or others.

The service providers I currently use include:

  • Fillout — acts as a data processor on my behalf, securely transmitting enquiries submitted through my website contact form.
  • Microsoft OneDrive — secure electronic record storage and encrypted backup.
  • Zoom and Microsoft Teams — online counselling sessions.

These providers process personal information only on my instructions or in accordance with their own legal obligations where applicable.

I have appropriate data processing arrangements in place with service providers where required under UK GDPR.

Where third-party providers process information on my behalf, I take reasonable steps to ensure appropriate security and data protection measures are in place.

9. Clinical will executor

In the event of my death, serious illness or incapacity that prevents me from managing my practice, I have arrangements in place with a nominated clinical will executor (also known as a professional executor).

The clinical will executor will only access the personal information necessary to:

  • inform clients that I am no longer able to provide counselling;
  • assist with the safe closure or transfer of my practice where appropriate;
  • arrange for the secure retention, transfer or confidential destruction of client records in accordance with my professional, legal and insurance obligations.

The clinical will executor is bound by strict duties of confidentiality and data protection and will only process personal information for these limited purposes.

10. How your information is stored and protected

I take appropriate technical and organisational measures to protect your personal information against unauthorised access, loss, misuse or disclosure.

Electronic records are stored on password-protected devices accessible only to me. Where appropriate, I also use encryption, multi-factor authentication and up-to-date security software to help protect personal information. Electronic records are securely backed up using Microsoft OneDrive. Backups are encrypted.

Paper records, where used, are stored securely and are accessible only to me.

I take reasonable steps to ensure that the personal information I hold is accurate, relevant and kept up to date where appropriate.

11. How long I keep your information

If you become a client, I normally retain counselling records for seven years after your final contact with me.

Clinical records may include assessment information, brief session notes, risk assessments, correspondence relating to your therapy and administrative records necessary for the safe management of your counselling.

This retention period reflects my professional and insurance requirements.

After this period, records are securely deleted or destroyed unless I am legally required to retain them for longer.

Financial records are retained for the period required under UK tax legislation.

If you enquire about counselling but do not become a client, I will retain your enquiry only for as long as reasonably necessary to respond to you and manage my records before securely deleting it, unless I am legally required to retain it for longer.

12. Communication

I may communicate with you using:

  • email;
  • telephone call;
  • text message;
  • WhatsApp.

These methods are used primarily for arranging appointments and other administrative matters rather than therapeutic work.

If you contact me using WhatsApp, your messages are protected by end-to-end encryption provided by WhatsApp.

Although I take reasonable steps to protect your privacy, electronic communication cannot be guaranteed to be completely secure or free from interception.

13. Online counselling

I offer online counselling using:

  • Zoom;
  • Microsoft Teams.

Clients are encouraged to attend online sessions from a private location where confidentiality can be maintained.

14. Website privacy

My website provides information about my counselling practice and allows prospective clients to contact me.

My website does not currently use cookies for analytics, advertising or visitor tracking. It is provided primarily to offer information about my counselling practice and to allow prospective clients to contact me through a secure enquiry form.

If cookies or other tracking technologies are introduced in the future, this Privacy Notice and any related cookie information will be updated accordingly.

My website hosting provider automatically collects limited technical information, such as IP addresses, browser information and server logs, to maintain the security and operation of the website.

This information is not used by me for marketing purposes or to identify individual website visitors.

If you submit an enquiry through my website contact form, your information is securely processed through Fillout before being sent to me.

Information submitted through the contact form is used only to:

  • respond to your enquiry;
  • arrange an initial consultation;
  • communicate regarding counselling services.

It is never used for marketing purposes.

15. International transfers

Some service providers I use, including Microsoft OneDrive, Microsoft Teams, Zoom and Fillout, may process or store information outside the United Kingdom.

Where personal information is transferred outside the UK, I rely on appropriate safeguards in accordance with UK GDPR. These safeguards may include:

  • UK adequacy regulations;
  • the UK International Data Transfer Agreement (IDTA);
  • the UK Addendum to the European Commission Standard Contractual Clauses;
  • other lawful transfer mechanisms permitted by UK GDPR.

16. Your data protection rights

Under UK data protection law, you have rights including:

  • the right to be informed;
  • the right of access;
  • the right to rectification;
  • the right to erasure in certain circumstances;
  • the right to restrict processing;
  • the right to object to certain processing;
  • the right to data portability where applicable;
  • the right to withdraw consent where consent is the lawful basis for processing.

These rights are not absolute. There may be circumstances where I am required to continue processing or retaining information because of legal, professional or insurance obligations.

Clinical notes are professional records created to support the safe and effective delivery of counselling. While you have rights of access under data protection legislation, there may be circumstances where exemptions under the Data Protection Act 2018 apply, or where disclosure could cause serious harm to you or another person.

If you wish to exercise any of your rights, please contact me. I will normally respond within one calendar month in accordance with UK data protection legislation.

If you have concerns about how I have handled your personal information, you may also make a data protection complaint using the process described in Section 17.

17. Complaints

If you have concerns about how I process your personal information, please contact me first so that I have the opportunity to resolve your concerns.

You also have the right to complain to the Information Commissioner's Office (ICO).

Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
Website: www.ico.org.uk

18. Changes to this Privacy Notice

I may update this Privacy Notice from time to time to reflect changes in legislation, professional guidance or the way my practice operates.

The most recent version will always be available on my website or provided on request.


Last updated 8 July 2026