Who we are

Counsel of Neurodivergent Minds Ltd is the data controller for the personal information you share with us.

Registered in England and Wales. Company number: 17231849. Registered office: 25 NE159SJ.

Contact: hello@counselofneurodivergentminds.co.uk

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What personal data we collect

Depending on how you interact with us, we may collect the following:

• Contact information - name, email address, phone number
• Enquiry and communication content - messages you send us
• Booking information - appointment preferences and scheduling data via Kiku
• Health and wellbeing information - relevant background shared in the context of counselling sessions (this is special category data under UK GDPR)
• Session notes - brief, confidential records kept as part of professional practice

We do not collect data from children directly. If you are under 18, a parent or guardian should be involved in any initial contact.

Why we collect it and our lawful basis

We process your personal data under the following lawful bases set out in the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018:

• Contract - to provide counselling services you have engaged us for
• Legitimate interests - to respond to enquiries and manage our practice
• Legal obligation - where we are required to retain or disclose information by law (for example, in safeguarding situations)
• Vital interests - in circumstances where disclosure is necessary to protect someone's life

For special category data (health information shared in a counselling context), we rely on Article 9(2)(h) of UK GDPR - processing necessary for the provision of health or social care - alongside your explicit consent where appropriate.

How we store and protect your data

Your data is stored securely. Session notes and personal records are kept in password-protected systems. Paper records, if any, are stored in a locked location with restricted access.

We take reasonable technical and organisational steps to protect your data against unauthorised access, loss, or disclosure. No transmission over the internet is completely secure, but we take this responsibility seriously.

How long we keep your data

We follow the retention guidance issued by professional counselling bodies:

• Adult client records - retained for 7 years after the end of the therapeutic relationship
• Records relating to minors - retained until the individual's 25th birthday, or 7 years after the end of the therapeutic relationship if that is later
• General enquiry data - deleted within 12 months if no therapeutic relationship was established

After these periods, data is securely deleted or destroyed.

Who we share your data with

We do not sell, rent, or trade your personal data. We may share limited information in the following circumstances:

• Clinical supervision - we discuss client work with a qualified supervisor as required by our professional code of ethics. This is done anonymously wherever possible.
• Legal or safeguarding obligations - where we are required by law, or where there is a serious risk of harm to you or another person, we may disclose information to appropriate authorities without your consent.
• Third-party booking services - appointment data may be processed by Kiku in accordance with their own privacy policy.

Website analytics

This website uses Cloudflare Web Analytics, a privacy-first analytics tool that does not use cookies, does not track individuals across websites, and does not collect personal data. No cookie consent is required for this. Cloudflare's privacy policy is available at cloudflare.com/privacypolicy.

Cookies and local storage

This website does not use tracking cookies. The dyslexia-friendly display toggle uses your browser's local storage - a mechanism that stores a simple preference (on or off) on your own device only. This data never leaves your device and is not accessible to us.

Your rights

Under UK GDPR and the Data Protection Act 2018, you have the following rights:

• Right of access - request a copy of the personal data we hold about you
• Right to rectification - ask us to correct inaccurate or incomplete data
• Right to erasure - request deletion of your data where there is no lawful reason to retain it
• Right to restrict processing - ask us to limit how we use your data in certain circumstances
• Right to data portability - receive your data in a commonly used, machine-readable format
• Right to object - object to processing based on legitimate interests
• Rights related to automated decision-making - we do not carry out automated decision-making or profiling

To exercise any of these rights, please contact us at hello@counselofneurodivergentminds.co.uk. We will respond within one month.

How to complain

If you have concerns about how we handle your personal data, please contact us in the first instance and we will do our best to resolve your concern.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's independent supervisory authority for data protection:

• Website: ico.org.uk
• Telephone: 0303 123 1113

Changes to this policy

We may update this privacy policy from time to time. Any changes will be posted on this page with an updated date at the top. We encourage you to review this page periodically.