Privacy Notice
Last updated: June 2026
This privacy notice explains how Annamai Martinot Counselling collects, uses, stores and protects personal information about prospective clients, current clients, former clients, website visitors, newsletter subscribers, emergency contacts and other people who contact us.
Introduction
Annamai Martinot Counselling is committed to protecting your privacy and handling your personal information lawfully, fairly and transparently.
This privacy notice explains what personal information we collect, why we use it, the lawful bases we rely on, who we may share it with, how long we keep it, and what rights you have.
We do not sell personal data. We only use personal data where we have a lawful reason to do so under UK data protection law.
About us
Annamai Martinot Counselling is the data controller for the personal information described in this privacy notice.
Data controller registration number: ZB517521
Our privacy contact is:
Annamai Martinot Counselling
Office 3, The Library Rooms
59 High Street
Totnes
TQ9 5PB
You can contact us about privacy or data protection matters by using the contact form on our website. Please mark your message “Privacy / Data Protection” so that it can be identified and dealt with appropriately.
What information we collect
We may collect and use the following types of personal information, depending on your relationship with us:
Name, address, email address, telephone number and other contact details and emergency contact details
Enquiries, enquiry information
Records of sessions, Clinical session notes, assessment forms, and therapeutic agreements.
Attendance records, assessment records.
Payment information, including invoices, outstanding balances and payment history
Communication records, including emails, text messages, contact forms and other correspondence
Website and analytics information, such as how visitors use our website
Information you choose to provide about wellbeing, health, disability, support needs, access needs or other circumstances relevant to your sessions, participation or safety
Special category data
Some of the information we collect may be more sensitive. This may include information about health, disability, wellbeing, support needs, safeguarding concerns, reasonable adjustments, or other information you choose to tell us because it is relevant to your sessions, participation or safety.
We only collect this information where it is necessary and appropriate. We use it to support clients, manage access needs, meet safeguarding or legal responsibilities, and help ensure that counselling is delivered safely and appropriately.
Where we process special category data, we identify both a lawful basis under UK GDPR and a separate condition for processing special category data.
We keep special category data under review and restrict access to those who need it for their role.
How we collect your data
We collect personal data directly from you:
When you first contact me to enquire about therapy (via email, telephone, or the website contact form)
During our initial consultation and intake process
Throughout our therapy sessions as part of ongoing therapeutic work
Through any correspondence between us (emails, text messages, telephone calls)
I do not collect personal data about you from any third parties unless you have given explicit consent for this, or it is necessary for safeguarding purposes.
Why we process your data — lawful basis
Under UK data protection law, I must have a valid legal reason (lawful basis) to process your personal data. Because therapy involves health-related information, I rely on two legal bases:
Article 6 basis (general personal data):
Article 6(1)(b) UK GDPR — processing is necessary for the performance of the therapeutic contract between us. When you engage me as your counsellor, we enter into a contract for therapeutic services. I need to process your personal data to deliver those services.
Article 9 basis (special category health data):
Article 9(2)(h) UK GDPR — processing is necessary for the provision of health or social care treatment by a health professional. As a qualified counsellor, I am entitled to process your health-related information in order to provide therapy.
The additional condition required under UK law is found in DPA 2018 Schedule 1, Part 1, paragraph 2 (health or social care purposes). This processing is carried out by a qualified counsellor subject to the professional obligation of confidentiality under the code of ethics and practice of NCPS.
Professional obligations and CPD
I am required by NCPS to attend regular clinical supervision. Clinical supervision is an essential part of professional practice — it helps me reflect on my work and ensures I am providing you with the best possible care.
When I discuss my therapeutic work with my supervisor:
Your name and any identifying details are not shared with my supervisor
I use anonymised or pseudonymised case material only
My clinical supervision is provided by a qualified professional who is bound by the same confidentiality obligations as I am
My supervisor is bound by their own professional code of ethics and practice
I also share limited financial information (invoice data only) with an external accountant or bookkeeper for the purposes of managing my practice accounts. They do not have access to your therapy records or any clinical information.
Clinical will — what happens to your records if I am unable to practise
I am currently putting clinical will arrangements in place. A clinical will is a plan that ensures your records are handled appropriately if I become suddenly unable to practise due to serious illness, incapacity, or death.
Once these arrangements are finalised, I will inform you of the details. In the meantime, please be assured that your records remain confidential and securely stored.
Who we share your data with
I take your confidentiality seriously and keep your personal data within my practice wherever possible. However, I use the following third-party services which may process limited data on my behalf:
Squarespace — the platform this website runs on
Google Meet — for online video therapy sessions
Bi- Lateral Base — for online video therapy sessions
Each of these services is bound by a data processing agreement and their own privacy policies. Links to their privacy policies are available on request.
As described above, I also share:
Anonymised case material with my clinical supervisor
Invoice data with an external accountant or bookkeeper
I never sell your personal data to anyone.
How long we keep your data
I retain your personal data only for as long as necessary. The retention periods are:
Therapy records
This includes session notes and your therapy agreement. I retain these records for 6 years after our last session, in line with relevant legal requirements, professional guidance and standard professional indemnity insurance requirements.
Financial records
This includes invoices and payment records. I retain these records for 6 years to comply with HMRC and other legal requirements.
Website enquiries
If you contact me through my website but do not become a client, I retain your enquiry information for 12 months. This allows me to respond to your enquiry and, where appropriate, follow up with you.
Once the applicable retention period has ended, paper records are securely destroyed and electronic records are securely and permanently deleted.
Confidentiality exceptions
Everything you share with me in therapy is confidential. However, there are limited circumstances where I may need to share information without your consent:
Risk of serious harm — If I believe there is a serious and imminent risk of harm to you or to someone else
Safeguarding concerns — If I become aware of abuse or neglect involving a child or vulnerable adult
Legal requirement — If I receive a court order requiring me to disclose information
Wherever possible, I will discuss any disclosure with you first, unless doing so would itself put someone at risk.
Changes to this policy
I review this privacy policy annually and whenever my practices change. If I make any significant changes that affect how your personal data is handled, I will inform you directly.
If you have any questions about this policy or how I handle your personal data, please contact me at annamaimartinot@gmail.com
Your rights under UK GDPR
You have the following rights regarding your personal data:
Right to be informed — You have the right to know how I collect and use your personal data. This privacy policy fulfils that obligation.
Right of access — You can ask me for a copy of the personal data I hold about you. This is known as a Subject Access Request. Under the Data (Use and Access) Act 2025, I will conduct a reasonable and proportionate search when responding to your request.
Right to rectification — If any personal data I hold about you is inaccurate or incomplete, you can ask me to correct it.
Right to erasure — You can ask me to delete your personal data in certain circumstances. However, this right is not absolute. I may need to retain your records until the end of the applicable retention period where this is required by professional guidelines, insurance requirements, or law.
Right to restrict processing — You can ask me to limit how I use your data in certain circumstances.
Right to data portability — In certain circumstances, you can ask me to transfer your data to another organisation or directly to you in a commonly used format.
Right to object — You can object to certain types of processing. However, as I process your data under contractual and health-related legal bases, this right may be limited.
Rights related to automated decision-making — I do not use automated decision-making or profiling in my practice.
To exercise any of these rights, please contact me at annamaimartinot@gmail.com