Best Self Therapy : Wirral
Privacy Policy

1.0 Privacy Policy

 

Best Self Therapy : Wirral

Delyth Cole – Psychotherapeutic Counsellor & Hypnotherapist

 

Last updated: September 2026

 

1. About this Privacy Notice

 

Your privacy and confidentiality are important to me.

 

This notice explains how I collect, use, store, protect and, where necessary, share personal information when you contact or work with Best Self Therapy.

 

I aim to handle your information lawfully, fairly, transparently and in a way that respects the confidential nature of therapy.

 

This notice applies to people who enquire about or receive my counselling, psychotherapy and hypnotherapy services.

 

Separate terms may apply to purchasers of digital products and online courses.

 

2. Who Is Responsible for Your Information?

 

I am the data controller responsible for the personal information processed within my private practice.

 

Delyth Cole

Best Self Therapy : Wirral

Wellness

66 Argyle Street

Birkenhead

Wirral

CH41 6AF

 

Email: hello@bestselftherapy.co.uk

Telephone: 07743 440664

 

I am registered with the Information Commissioner’s Office (ICO).

 

3. Information I May Collect

 

The information I hold will depend on your contact with me and the services you use.

 

It may include:

 

• your name

• address

• email address

• telephone number

• date of birth

• emergency contact details

• GP or other relevant healthcare information where appropriate

• appointment dates and times

• payment and transaction information

• correspondence between us

• information submitted through my website or booking system

• information necessary to provide therapy safely and appropriately.

 

Therapy may involve information that UK data-protection law classifies as special category data, including information relating to your physical or mental health.

 

You may also choose to discuss other sensitive aspects of your life during therapy.

 

I aim to collect and retain only information that is reasonably necessary for the safe, ethical and effective provision of my services.

 

4. Therapy Records

 

I deliberately keep therapy records to a minimum.

 

My records primarily consist of administrative information, including appointment dates and times, together with brief information or notes where I consider these necessary for safe, ethical and effective practice.

 

Where handwritten or other clinical notes are created, I take appropriate steps to store identifying information separately wherever practicable.

 

I do not routinely create detailed narrative reports of everything discussed during therapy.

 

5. How I Collect Information

 

I may receive information:

 

• directly from you

• during an initial enquiry or consultation

• through my website

• through my online booking system

• by email, telephone, text or WhatsApp, or Instagram messaging

• during therapy sessions

• through forms or contracts you complete

• from another person or professional where you have authorised this or where another lawful basis applies.

 

6. Why I Use Your Information

 

I use personal information where necessary to:

 

• respond to enquiries

• assess whether I can appropriately provide the service you are seeking

• arrange and manage appointments

• provide counselling, psychotherapy or hypnotherapy

• communicate with you about our work

• maintain appropriate professional records

• manage payments and administration

• maintain safe and ethical professional practice

• undertake professional supervision

• respond appropriately to safeguarding or serious-risk situations

• meet legal, regulatory, insurance or professional obligations

• establish, exercise or defend legal claims where necessary.

 

I will not sell your personal information.

 

I will not use therapy information for unrelated marketing purposes.

 

If I send marketing communications, I will do so only where I have an appropriate lawful basis and you will be able to withdraw from those communications.

 

7. Lawful Basis for Processing

 

UK data-protection law requires me to identify an appropriate lawful basis for processing personal information.

 

Depending on the circumstances, this may include:

 

• processing necessary to enter into or perform our therapeutic contract

• compliance with a legal obligation

• my legitimate interests in operating a safe, ethical and properly administered private practice

• your consent where consent is the appropriate lawful basis

• another lawful basis available under UK data-protection legislation.

 

Additional legal conditions apply when processing special category information, such as health information.

 

The appropriate legal basis depends on the purpose and circumstances of the processing. I will not rely on consent simply because information is sensitive where another legal basis is more appropriate.

 

8. Confidentiality

 

Confidentiality is a fundamental part of the therapeutic relationship.

 

Information you share with me during therapy is treated as confidential.

 

There are, however, circumstances in which I may need to consider sharing information. These may include:

 

• a serious risk of harm to you or another person

• safeguarding concerns

• circumstances where disclosure is required or permitted by law

• a court order or other legally enforceable requirement

• professional supervision.

 

Confidentiality is not automatically broken simply because a difficult situation arises.

 

I will consider the circumstances carefully, including your wishes, the level and immediacy of risk, my ethical responsibilities and any relevant legal obligations.

 

Where it is safe, lawful and appropriate to do so, I will aim to discuss a proposed disclosure with you beforehand.

 

Where information needs to be shared, I will aim to disclose only information that is relevant and necessary for the purpose.

 

9. Professional Supervision

 

Professional supervision is an important part of safe and ethical therapeutic practice.

 

I attend regular professional supervision and may discuss aspects of my therapeutic work with my supervisor.

 

Where possible, information is anonymised or minimised so that clients are not unnecessarily identifiable.

 

My supervisor is also required to maintain appropriate professional confidentiality.

 

10. Digital Services

 

I use appropriate digital services to support the administration and delivery of my practice.

 

These may include services for:

 

• website hosting and website enquiries

• appointment booking

• email and electronic communication

• online therapy

• secure storage and administration

• payment or accounting administration.

 

Services currently used may include Wix, Calendly and Zoom.

 

These services may process limited personal information required to provide their functions.

 

I periodically review the digital services I use and take reasonable steps to consider their privacy, confidentiality and security arrangements.

 

Where a service processes information outside the UK, I will take reasonable steps to ensure that an appropriate lawful mechanism for international data transfers is in place where required.

 

Third-party services have their own privacy notices explaining how they process information within their systems.

 

11. Artificial Intelligence (AI)

 

Artificial intelligence and other digital tools will not be used to replace my professional judgement, clinical decision-making, professional supervision or the therapeutic relationship.

 

Before using an AI or digital tool in a way that could involve client information, I will consider the purpose of the tool and the potential implications for privacy, confidentiality, data protection and professional ethics.

 

I will not knowingly enter personally identifiable confidential therapy material into a generative AI system without first establishing an appropriate ethical and data-protection basis and, where required, obtaining your informed consent.

 

Where the use of an AI or digital tool could materially affect your privacy, confidentiality or therapeutic experience, I will aim to explain its purpose and any reasonably foreseeable benefits or risks before using it.

 

Responsibility for the professional decisions I make remains with me and is not delegated to an AI system.

 

12. Automated Decision-Making

 

I do not use automated decision-making or profiling to make decisions about whether or how therapy is provided to you.

 

13. Online Therapy

 

Online therapy is normally provided through Zoom.

 

Although I take reasonable steps to use appropriate privacy and security settings, no form of internet communication can be guaranteed to be completely private or secure.

 

Online sessions are not recorded by me.

 

Clients must not record therapy sessions without my prior agreement.

 

You are responsible for choosing an appropriately private environment for your online session. I will also conduct online sessions from an appropriate private setting.

 

14. WhatsApp, Text Messages, Email and Instagram Messaging 

 

If you choose to communicate with me by WhatsApp, text message or email, please be aware that these methods involve third-party communication services.

 

I recommend using messages primarily for practical matters such as arranging appointments rather than sending extensive sensitive therapeutic information.

 

If you contact me using one of these methods, I may reply using the same method unless you ask me to use another agreed means of communication.

 

15. Couples Therapy and Information About Other People

 

Couples therapy necessarily involves information relating to more than one person.

 

Records may therefore contain personal information relating to both partners.

 

Data-protection rights still apply, but providing one person with information contained in a joint record may affect the privacy and data-protection rights of the other person.

 

Requests concerning couples records will therefore be considered individually and in accordance with applicable data-protection law.

 

Please also avoid unnecessarily providing me with sensitive personal information about third parties who are not involved in the therapy.

 

16. How I Protect Information

 

I take reasonable and proportionate measures to protect the information I hold.

 

Depending on the format, these may include:

 

• locked storage for paper records

• password-protected devices

• appropriate device security

• encryption where appropriate

• keeping software up to date

• limiting access to information

• separating identifying information from therapy information where reasonably practicable

• securely disposing of information when it is no longer required.

 

No storage or communication system can guarantee absolute security, but I take reasonable steps appropriate to the nature and sensitivity of the information I hold.

 

17. How Long I Keep Information

 

I do not keep personal information indefinitely.

 

My current retention periods are:

• Client records: normally retained for six years following the end of therapy or the last therapeutic contact.

• Enquiries that do not lead to therapy: normally retained for four weeks unless there is a legitimate reason to retain them for longer.

 

Some information may need to be retained for a different period where required by law, insurance requirements, safeguarding considerations, complaints, legal claims or another legitimate professional reason.

 

At the end of the applicable retention period, information will be securely deleted or destroyed.

 

18. Sharing Information

 

I do not routinely share client information with third parties.

 

Information may be shared where:

 

• you have asked or authorised me to do so

• it is necessary for professional supervision

• I am legally required to provide it

• an appropriate safeguarding or serious-risk justification exists

• it is necessary to establish, exercise or defend a legal claim

• a service provider needs limited information to provide a service to my practice.

 

Where third-party processors are used, I take reasonable steps to use services that provide appropriate data-protection safeguards.

 

19. International Data Transfers

 

Some technology providers may store or process information outside the United Kingdom.

 

Where UK data-protection law requires safeguards for an international transfer, I will take reasonable steps to ensure an appropriate transfer mechanism is being used.

 

The precise arrangements may depend on the provider and country involved and can change over time.

 

You are welcome to ask me for further information about the services currently used within my practice.

 

20. Your Data-Protection Rights

 

Depending on the circumstances, your rights may include the right to:

 

• ask whether I hold personal information about you

• request access to your personal information

• ask for inaccurate information to be corrected

• request deletion of information in certain circumstances

• request restriction of processing in certain circumstances

• object to certain forms of processing

• request data portability where applicable

• withdraw consent where processing is based specifically on consent

• complain about the way your personal information has been handled.

 

These rights are not absolute and exceptions may apply.

 

A request for access to information will also need to take account of information relating to other people and any applicable legal restrictions.

 

I may need to verify your identity before responding to a data-protection request.

 

Please contact me at hello@bestselftherapy.co.uk if you wish to exercise a data-protection right.

 

21. Website and Cookies

 

My website may use cookies and similar technologies necessary for its operation and, where applicable, to understand website use.

 

Where consent is legally required for non-essential cookies or similar technologies, you will be given an appropriate choice.

 

Please see the website’s cookie information or cookie settings for further details.

 

22. Data-Protection Concerns

 

If you are concerned about how I have handled your personal information, please contact me so that I have an opportunity to understand and respond to your concern.

 

You also have the right to raise a data-protection concern with the Information Commissioner’s Office (ICO).

 

Information about making a complaint and exercising your data-protection rights is available from the ICO.

 

23. Therapy Complaints

 

A concern about the therapeutic service itself is different from a data-protection complaint.

 

I am a Registered Member of the British Association for Counselling and Psychotherapy (BACP) and work in accordance with its Ethical Framework.

 

If you have a concern about our therapeutic work, I encourage you to discuss it with me where you feel able to do so.

 

Information about BACP’s Professional Conduct Procedure is available directly from BACP.

 

24. Changes to This Notice

 

I may update this privacy notice when legislation, professional guidance, technology or the way I operate my practice changes.

 

The current version will be published on the Best Self Therapy website.

 

Last updated: September 2026