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Privacy Policy
Sarah-Jane Warner Counselling & Coaching

Last updated: 21.10.2026
ICO Registration Reference: ZC263186

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1. About this privacy policy

Sarah-Jane Warner is a sole trader trading as Sarah-Jane Warner Counselling & Coaching, providing counselling and coaching to adults, online and in person.

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I am responsible for the personal information I collect and use in connection with my website, enquiries, counselling and coaching services and related business activities.

 

Contact:
Sarah-Jane Warner
Sarah-Jane Warner Counselling & Coaching
Sole Trader
Exeter, Devon
Email: sarah-jane@sjwarner.com

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This notice should be read alongside the relevant Counselling or Coaching Client Agreement and Website Terms & Conditions.

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2. Information I collect

Depending on the service and circumstances, I may collect:

  • your name, preferred name, date of birth and contact details;

  • information needed to arrange and manage appointments;

  • attendance, cancellation and appointment information;

  • payment and transaction information;

  • information provided when you make an enquiry;

  • information you share during counselling or coaching;

  • session notes, assessments and other professional records;

  • information concerning your health, wellbeing, safety, risk or support needs;

  • safeguarding information where relevant;

  • emergency contact details where appropriate;

  • relevant information about previous therapy, counselling, coaching or other professional support;

  • correspondence relating to your service;

  • information needed to deal with complaints, legal matters or professional issues.

 

I aim to collect only information that is relevant and necessary.

 

Please avoid putting detailed mental-health, medical or other sensitive information into website contact forms or other general communications unless specifically requested.

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3. Special category information

Counselling may involve health information and other sensitive information. Information concerning health is special category data and receives additional protection under UK data protection law.

 

I may process special category information where this is necessary and proportionate for the provision of counselling or coaching, maintaining appropriate professional records, professional supervision, safeguarding, client safety, responding to serious risks, complying with legal or professional obligations, or dealing with legal claims or other circumstances permitted by law.

 

Where I process special category information, I will rely on an appropriate lawful basis under Article 6 of the UK GDPR together with an applicable condition under Article 9 of the UK GDPR and, where required, the relevant provisions of the Data Protection Act 2018.

 

I will only process special category information to the extent that it is relevant and necessary for the particular purpose.

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4. How information is collected and used

Information may be collected directly from you through enquiries, booking, forms, email, telephone, sessions, payments and correspondence, or automatically through website technologies where applicable.

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I may use personal information to:

  • respond to enquiries;

  • assess and provide counselling or coaching;

  • arrange and manage appointments;

  • maintain appropriate professional records;

  • communicate with you about your service;

  • process and record payments;

  • support safe, ethical and professional practice;

  • undertake professional supervision or mentoring;

  • respond to safeguarding concerns or serious risks;

  • contact an emergency contact or emergency services where reasonably necessary to protect life, health or safety;

  • meet legal, professional, accounting or insurance requirements;

  • deal with complaints or legal claims;

  • maintain appropriate business records and protect my legitimate interests.

 

I do not use identifiable client information with artificial intelligence tools to analyse, summarise or transcribe counselling or coaching records.

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5. Lawful bases

Depending on the purpose, I may rely on the following lawful bases:

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Contract – where processing is necessary to provide the counselling or coaching service or to take steps at your request before entering into an agreement.

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Legal obligation – where I am required by law to collect, use or retain information, for example certain financial or accounting records.

 

Legitimate interests – where processing is necessary for appropriate professional, administrative or business purposes and is not overridden by your rights and interests.

 

For example, this may apply when dealing with queries, complaints or claims, maintaining appropriate records, protecting my practice and clients, or establishing, exercising or defending legal claims.

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Vital interests – where information needs to be used or shared to protect someone's life in an urgent or serious situation.

 

Consent – where I specifically ask for your consent and consent is the appropriate lawful basis.

Special category information requires an additional Article 9 condition as described above.

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6. Confidentiality, safeguarding and serious risk

I have a duty of confidentiality and take the privacy of counselling and coaching clients seriously.

 

Information will not normally be shared without your knowledge or consent. However, confidentiality cannot be guaranteed where information needs to be shared because of a serious safeguarding concern, serious or imminent risk of harm, a legal requirement, or another circumstance where disclosure is necessary and proportionate.

 

Depending on the circumstances, information may be shared with:

  • my professional supervisor or appropriate coaching supervisor/mentor;

  • relevant safeguarding or healthcare professionals;

  • emergency services;

  • professional or regulatory bodies where required or appropriate;

  • legal or law-enforcement authorities where legally required, authorised or necessary;

  • service providers processing information on my behalf.

 

Where possible and appropriate, I will discuss significant disclosures with you beforehand and will share only information that is relevant and necessary.

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7. Supervision

Counselling work may be discussed with my professional supervisor as part of safe and ethical practice. Peer supervision may also involve discussion of counselling work.

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I will normally anonymise information and will not normally share your name, contact details or unnecessary identifying information.

 

In exceptional circumstances, identifiable information may need to be discussed with a supervisor where this is necessary for safeguarding, serious risk, ethical decision-making or another significant professional concern.

 

Coaching information may similarly be discussed with an appropriate coaching supervisor or mentor as part of professional development, ethical practice or client safety.

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8. Website, cookies and online booking

My website uses Wix for website hosting, contact forms and online booking.

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If you submit information through a website contact form, it will be used to respond to your enquiry and may be processed by Wix as part of providing the website service.

 

Online bookings through Wix may include your name, contact details, appointment information and other information you choose to provide.

 

Please do not provide detailed health or other sensitive information through these facilities unless specifically requested.

 

The website uses cookies and similar technologies. Usercentrics provides the cookie consent management service, allowing you to manage applicable cookie preferences.

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9. Online counselling and coaching

Online sessions are provided using Zoom.

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Zoom is a separate service provider and processes information under its own privacy arrangements. I do not record online counselling or coaching sessions.

 

You are responsible for taking reasonable steps to ensure that you have a private and confidential environment for an online session.

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10. Payments and accounting

Payment for sessions is currently made by BACS bank transfer.

 

I may retain information such as your name, payment date, amount and payment reference in order to record and reconcile payments and maintain appropriate financial records.

 

I do not routinely require you to provide your full bank account details simply to make a BACS payment.

 

I use FreeAgent for accounting and financial management. My accountant may have access to relevant financial information held in FreeAgent where necessary to provide accounting services.

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11. Data processors and other organisations

I use service providers that process personal information on my behalf, including:

  • Wix – website hosting, contact forms and online booking;

  • Usercentrics – cookie consent management;

  • Zoom – online video conferencing;

  • Google Workspace – email and related communication services;

  • FreeAgent – accounting and financial management.

 

Other organisations or individuals may receive relevant personal information where necessary, including:

  • my accountant, where necessary for accounting and financial services;

  • my professional supervisor or coaching supervisor/mentor;

  • relevant safeguarding or healthcare professionals;

  • emergency services;

  • professional or regulatory bodies where required or appropriate;

  • legal or law-enforcement authorities where legally required, authorised or necessary.

 

Information will only be shared where there is an appropriate lawful basis and only to the extent reasonably necessary for the relevant purpose.

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Practice continuity

If I become unable to continue my practice due to illness, incapacity or death, my professional supervisor may help manage the appropriate closure of my practice. This may include accessing relevant records where necessary and contacting clients to explain the situation and any next steps. Any access to or sharing of information will be limited to what is necessary and handled in accordance with confidentiality and applicable legal and professional responsibilities. Further details are set out in my Clinical Will.

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12. International transfers

Some of my service providers may process personal information outside the UK.

 

Where this occurs, appropriate safeguards or an applicable adequacy decision will be relied upon in accordance with UK data protection law.

 

Information about relevant international transfers and safeguards can be provided on request.

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13. How information is stored and protected

I take reasonable and appropriate measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

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Paper records are stored securely in a locked filing cabinet. Electronic information is protected using appropriate account, password, device and access-security measures.

 

Access to information is limited to people who have a legitimate reason to access it.

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14. How long information is kept

Client counselling and coaching records are normally retained for seven years after the end of the professional relationship.

 

Different types of information may be retained for different periods where appropriate. Financial records will be retained for the period required by applicable legal and accounting requirements.

 

Information will not be retained indefinitely and will be securely deleted or destroyed when it is no longer required, unless there is a lawful reason to retain it for longer.

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15. Your data protection rights

Depending on the circumstances, you may have rights under UK data protection law including the right to:

  • request access to your personal information;

  • ask for inaccurate information to be corrected;

  • request deletion in certain circumstances;

  • request restriction of processing in certain circumstances;

  • object to certain processing;

  • request data portability where applicable;

  • withdraw consent where processing is based on consent.

 

These rights are subject to legal conditions and exemptions.

 

To exercise a right or ask a question about your personal information, contact:

sarah-jane@sjwarner.com

I may need to verify your identity before responding. Requests will normally be responded to within one month, subject to applicable legal requirements and exemptions.

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16. Complaints

If you have concerns about how I have handled your personal information, you can complain to me by email:

sarah-jane@sjwarner.com

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You do not have to complain to me before contacting the Information Commissioner's Office (ICO).

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You can complain directly to the ICO if you believe your personal information has been handled unlawfully or your data protection rights have not been respected.

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17. Changes to this policy

This privacy policy may be updated when there are significant changes to my services, how information is handled, technology, professional requirements or data protection law.

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The date at the beginning of the notice will be updated when significant changes are made.

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18. Contact

If you have any questions about this privacy policy or how your personal information is handled, please contact:

 

Sarah-Jane Warner
Sarah-Jane Warner Counselling & Coaching
Sole Trader
Exeter, Devon
sarah-jane@sjwarner.com

Professional membership: MBACP
Membership number: 422837

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