Privacy Policy

Janet Smith Emotional Wellness Coaching holds confidentiality as an extremely important and integral part of my practice.

In accordance with new GDPR legislation, I am fully compliant and have detailed the procedures of how I deal with your data and my commitment to the security of your data.
Working with my clients it is necessary for me to collect personal data to assist the therapeutic journey. I will only collect relevant data necessary for this.

Janet Smith Emotional Wellness Coaching will ensure that:

  • I only collect and process data that is needed.
  • I only use personal data as described in this document and client contract and only for the purposes that it is legally permitted.
  • I will strive to keep accurate information and review with you your personal details periodically to ensure this.
  • I will not keep your information past 3 years from working with me.
  • I will not keep your emails, text messages longer than 3 months unless required for therapeutic reasons and in agreement between us.
  • I will securely destroy data
  • I will take steps to always provide security of your data.
  • I will not share your personal data unless requested to do so by Court Order.

Information I hold

I will only collect and maintain the personal data for clients that includes name, date of birth, telephone number, email address, relevant medical information, personal information relating to current wellbeing, historical and other important factors to assist in supporting client. I will take brief, factual notes during our sessions.

Lawful basis holding your data

In accordance with the new GDPR legislation I need to have a lawful basis for holding your data. My lawful basis for holding your data is:

  • to support the ongoing therapeutic work of clients.
  • to assist in the continuity of therapy by giving a brief factual overview of what happened in our session.
  • to keep you focused on your goals and aspirations.
  • to maintain details of your emotional life history (periods where you have experienced significant pain or pleasure). • to note any impactful relationships or events that are triggers for negative behavioural patterns.
  • to keep a record of interventions (exercise) used and the outcome of them, to ensure I do not repeat an intervention and use the outcome to assist your personal development and growth.
  • To communicate regarding session times/location of sessions and send reminder via text messaging.
  • To communicate other resources via email, which will assist your emotional wellbeing, such as articles, web links, and reading list.
  • To take notes to Supervision (professional consultation required for all counsellors) which maintains my ability to practice ethically and protects us both.
  • I hold client notes and personal data for 3 years after the therapeutic work has concluded. The lawful basis for this is to assist the client should they wish to resume working with me at any time in the future.

Individual’s rights

  • Under the GDPR, clients have:
  • The right to be informed;
  • The right of access;
  • The right to rectification;
  • The right to erasure;
  • The right to restrict processing;
  • The right to data portability;
  • The right to object; and
  • The right not to be subject to automated decision-making including profiling.

How I hold your data and destroy it

  • I hold personal data for a period of 3 years following client’s last session.
  • Data will be destroyed by authorised confidential document disposal company.
  • Paper records of personal details are maintained and stored in locked, fire proof cabinet.
  • Session records are stored on the cloud. The records are transmitted using SSL, (secure socket layer) encrypted line. The records Data warehouse is compliant with data warehouse security protocol and process, including access controls, encryption, firewalls, and recurring security audits.
  • Text messages and emails are deleted every 3 months.
  • Initial enquiry forms are held for 10 days from initial call and either become part of the client records or are destroyed by authorised confidential document disposal company if the enquirer does not become a client.


I will ask you to complete a Personal Details form giving your specific consent to collect and process your data. You have the right to refuse consent.


Clients may wish to leave a testimonial directly on my website or send to me via email.  Cli They can be anonymous if requested.  Clients may also leave a google or facebook review. I may use these for marketing purposes as well as offering hope to new clients looking for support via my website. It is not compulsory to leave a testimonial on conclusion of therapy.

Data Breach

Whilst every effort is made to protect client data, in the unlikely event of a data breach where it is likely to result in a risk to the rights and freedoms of individuals, I will contact ICO immediately and contact the client to advise of the data breach.

Under the GDPR I review and audit my personal data policies and procedures regularly and audit every 6 months.

Data portability

Should you wish to have your data sent to a third party, I will require a request in writing. I will send data via the Internet but please bear in mind that data transfer cannot be guaranteed to be 100% secure.

How to complain

Individuals have a right to complain to the ICO if they think there is a problem with the use of their personal data.

Further information can be found under GDPR regulations and I am happy to discuss any of the details of this Privacy policy at any time.

Janet Smith Emotional Wellness Coaching

Tel: 07966 552439

Practicing face 2 face at my garden office in Waterlooville and virtual appointments available throughout the UK and internationally via Skype, Face Time, What’s app or telephone call.

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