Privacy Policy

At Number 22 we want everyone who supports us, or who receives a service from us, to feel confident about how we use and protect any personal information that you share with us. This privacy notice is intended to explain how we collect and process data in compliance with the Data Protection Act 2018, the UK’s implementation of the General Data Protection Regulation (GDPR). 

We are committed to protecting your personal data and making sure that we collect only the data that we need, that it is processed in a fair, transparent and lawful manner, that it is kept no longer than necessary and that it is thereafter securely destroyed. We will never sell or share your personal data with other organisations for marketing purposes. 

We’ve implemented appropriate physical, technical and organisational measures to protect the personal data we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss. 

1. Who We Are 

Number 22 is a counselling agency providing therapeutic support to adults, children and young people in educational and healthcare settings. 

We are registered with the Information Commissioner’s Office (ICO). Our registration number is: ZB329707

2. What Data We Collect

We may collect and process the following types of personal data: 

Personal Information 

• Full name 

• Date of birth 

• Ethnicity 

• Gender 

• Contact details (address, email, phone number) 

• Emergency contact details 

• GP or school details (if applicable) 

Special Category Data (Sensitive Information) 

• Mental and physical health information 

• Counselling session notes 

• Information about family, relationships, education, and social circumstances 

• Safeguarding concerns  

As part of our counselling service, we ask clients to complete a recognised outcome measure at the beginning and end of their counselling intervention. Adults are asked to complete the CORE-10 (Clinical Outcomes in Routine Evaluation) and children and young people are asked to complete the YP-CORE (Young Person’s Clinical Outcomes in Routine Evaluation). When working with children under the age of 11 in schools, we ask their teacher to complete the Goodman’s Strength and Difficulties questionnaire.  

These questionnaires help us understand a client’s wellbeing, monitor progress during counselling, evaluate the effectiveness of our services, and identify areas for service improvement. We process this information under Article 6(1)(f) UK GDPR (legitimate interests) and, where the information relates to an individual’s mental health, under Article 9(2)(h) UK GDPR (the provision of health or social care or treatment) and/or Article 9(2)(j) UK GDPR (statistical and research purposes), as applicable. The information collected is treated as special category personal data and is processed securely, confidentially, and only by authorised staff in accordance with the UK GDPR, the Data Protection Act 2018, and our data protection 

3. How We Collect Your Data

We collect personal data through: 

• Referral forms (self, school, GP, or other professionals) 

• Initial assessments 

• During counselling sessions 

• Communication via phone, email, or our website 

• Parents/carers or school staff, in the case of children and young people

4. Legal Basis for Processing

Under the UK GDPR, we rely on the following lawful bases: 

• Consent: where you have given clear consent for us to process your personal data for a specific purpose. 

• Contract: processing is necessary for the performance of a contract with you. 

• Legal obligation:  for safeguarding and reporting concerns where required by law. 

• Vital interests: to protect someone’s life. 

• Legitimate interests: in delivering and improving our services. 

• Special category data: for the provision of health or social care services. 

5. How We Use Your Data

We use your data to: 

• Provide safe and effective counselling support 

• Communicate with you about appointments and service updates 

• Monitor progress and outcomes of therapy 

• Work collaboratively with schools and professionals (with consent where appropriate) 

• Fulfil safeguarding responsibilities 

• Maintain accurate records for legal and clinical governance, in accordance to the Ethical Framework of the British Association of Counsellors and Psychotherapists, of which Number 22 is an accredited member. 

6. Sharing Your Information

We treat your data with strict confidentiality. We only share your information: 

• With your explicit consent 

• Where there is a risk of significant harm to you or others 

• If required by law (e.g., court order, safeguarding legislation) 

• With school staff, GP, or other professionals, where appropriate and with your agreement 

We do not sell or share your information for marketing purposes. 

7. Data Retention

We retain counselling records for a period of 7 years after the last contact. For children and young people, this will be until they reach age 25, whichever is later. The process is in line with professional guidelines. After this period, records will be securely destroyed. 

8. Your Rights

You have the following rights under data protection law: 

• The right to be informed about how your data is used 

• The right of access to your personal data 

• The right to rectification of inaccurate or incomplete data 

• The right to erasure (in certain circumstances) 

• The right to restrict processing 

• The right to data portability 

• The right to object to processing 

• Rights related to automated decision-making and profiling (we do not use automated profiling) 

You can exercise these rights by contacting us at: [email protected] 

We will respond to Subject Access Requests within one calendar month of receipt. Where we need to verify your identity before processing your request, the one-month period will not begin until we have received the necessary proof of identity.