Policies and Safeguarding
Rosetta Counselling client privacy notice
This privacy notice tells you what to expect us to do with your personal information.
Contact details
What information we collect, use, and why
Lawful bases and data protection rights
Where we get personal information from
How long we keep information
How to complain
What information we collect, use, and why
We collect or use the following personal information to protect client’s welfare:
Names and contact information
Health and wellbeing information
Emergency contact details
We also collect or use the following special category information to protect client welfare. This information is subject to additional protection due to its sensitive nature:
Health information
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to protect client welfare are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
I collect personal information so I can assess if the client is suitable for counselling at this point in time. So, I know if the client is working with other organisation’s that might cause a conflict with my practice or to gain further information about the clients history.
Also to be able to safeguard the client by contacting appropriate support that I deem is required.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Where we get personal information from
Directly from you
How long we keep information
In accordance with my insurance company, I store client information for 7 years, and after this time all information is deleted or destroyed.
For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
How to complain
If you have any concerns about our use of your personal information, you can make a data protection complaint to us:
Email: rosettacounselling@gmail.com
Telephone: 07503117615
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
ICO Head Office
4th Floor, No.3 Circle Square
5 Hawkshaw Street
Manchester
M1 7BL
Helpline number: 0303 123 1113
Safeguarding Policy and Procedure
Practice name – Rosetta Counselling
Practitioner – Vickie Gore
Policy Review – October 2026
Purpose and Scope
The purpose of this policy is to protect clients from abuse, harm and neglect. This policy sets out the framework for how Rosetta Counselling identifies safeguarding concerns, manages risk, and balances client confidentiality with legal and ethical duties. This policy applies to online and telephone. It is aligned with the Children Act 1989/2004, the Care Act 2014 and the ethical framework of the BACP
Definition of vulnerability and Abuse
For the purpose of this practice, safeguarding duties apply to Children and Young People – Anyone under the age of 18
Adults at Risk – Anyone aged 18 or over who has care and support needs, is (or is at risk of) abuse or neglect, and is unable to protect themselves because of those needs.
Policy on Confidentiality and its limits
Confidentiality is fundamental to the therapeutic relationship. However, confidentiality is not absolute and will be breached if there is an overriding legal or ethical duty to protect life or prevent significant harm.
Information will be shared with your agreed contact, GP or the police under the following circumstances
Risk to self: There is clear and imminent evidence that the client intends to end their life or cause severe, irreversible self-harm.
Risk to others /Public Interest: There is clear evidence that the client poses an imminent danger of serious harm to another person.
Child Protection: There is a disclosure, suspicion, or evidence that a child (under 18) is experiencing, or is at risk of experiencing, abuse or neglect.
Adult at Risk: There is evidence that an adult at risk is experiencing, or is at risk of experiencing, abuse or neglect.
Statutory Mandate: A legal requirement to disclose information arises under the Terrorism Act 2020, Drug Trafficking Acts, or if ordered by a court subpoena.
Safeguarding Procedures (The 5 Rs)
In the event of a safeguarding concern or disclosure, Rosetta Counselling follows a strict five-step process.
Recognise: Stay alert to signs, symptoms, behavioural changes, or direct disclosures indicating abuse, neglect or severe risk.
Respond: Listen to the client without judgement. Inform them transparently if their disclosure crosses the threshold where confidentiality must be breached. Do not investigate or cross examine the client.
Record: Document the concern immediately (within 24 hours). Write a factual, objective, and timed case note using the client’s exact words where possible. Keep the records strictly confidential and separate from general therapeutic notes.
Report/Consult: Immediately contact my clinical supervisor to review the ethical dimension of the risk.
Refer: If the threshold is met, a referral is made to the appropriate agency/service.
Safe storage and Date Compliance:
All safeguarding records, disclosure forms, and correspondence are handles in strict compliance with the Data Protection act 2018/ UK GDPR
Client personal details and session notes are stored on a device that only accessible to me the practitioner. This device is password protected and not connected to the internet. I do not use AI in connection with any client notes or details I record. All my clients are given a code so only I can identify them. Client details such as name and address are kept separately from any session/process notes I take, to protect client confidentiality. In line with professional guidance, a therapeutic executor has been appointed to securely manage and access client records in the event of my sudden death or incapacitation.
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