Privacy Policy
Evolve Counselling & Psychotherapy
Version: 3.0
Effective date: November 2026
Review date: January 2028
Privacy Policy
This explains what information we use, why we need it, how we protect it, and your choices. It applies to people who contact Evolve and to clients receiving individual counselling or couples therapy (couples sessions are in person or by video, not by telephone). We respect your privacy and keep information to a minimum.
1 Who is responsible for your information?
Evolve is a collective of self-employed therapists. Each therapist is responsible for the client information and therapy records they hold and acts as an independent data controller for their practice, with their own ICO registration. Each therapist deals directly with privacy questions, data-rights requests and data-protection complaints about information they hold. Evolve handles general website enquiries and shared administration; its general email address is for enquiries, not clinical privacy complaints.
2 What information do we collect?
Depending on what is needed, this may include your name and contact details; date of birth; appointment and payment information; GP or emergency-contact details; relevant health or personal information you choose to share; and brief therapy or safeguarding records where appropriate.
Therapists keep only brief factual notes of routine sessions where necessary, not detailed accounts of what clients say. This helps protect privacy, while ensuring that significant safeguarding concerns and decisions are recorded sufficiently to explain any action taken. Notes can still be personal information even without a client's name.
In couples therapy, brief notes may concern both people or separate safety conversations. Joint therapy notes are not voluntarily shared with either partner, and private disclosures are not automatically passed between partners.
Enquiries and website use may also produce correspondence, basic usage data and technical information such as an IP address. Sometimes relevant information is received from a referrer or another professional, where appropriate.
3 Why do we use it?
We use information to respond to enquiries, arrange and provide therapy, manage payments, keep necessary records, protect safety, and meet legal or professional duties. We do not sell client information or use therapy information for advertising.
Our usual legal bases under UK data-protection law are: taking steps towards or performing a therapy contract; meeting legal duties (including accounting); and legitimate interests in handling enquiries and providing safe, responsible services. In an emergency, vital interests or another appropriate legal basis may apply.
Sensitive information, including health information, has extra protection. Where the conditions are met, we use it for confidential counselling or psychotherapy under UK GDPR Article 9(2)(h) and the applicable legal duty of confidence. Therapists follow the professional standards relevant to their BACP or COSCA membership. Other legal conditions may apply for safeguarding or legal claims. Agreeing to therapy does not mean that consent is the legal basis for every use of data.
4 Confidentiality and sharing
Therapy is confidential, but confidentiality is not absolute. Your therapist may share relevant information without your consent, including if you disagree, where the law allows or requires this and disclosure is necessary and proportionate — for example, to respond to serious harm, protect a child or an adult at risk, or comply with a court order. Wherever practicable and safe, your therapist will discuss this with you first.
Therapists discuss their work in confidential supervision, avoiding identifying details wherever practicable. When necessary, information may be shared with emergency, health or safeguarding services. Email, video, booking, payment and storage providers may process limited information under appropriate arrangements.
If a therapist dies or unexpectedly becomes unable to practise, a named Therapeutic Executor may securely access only the contact details needed to inform clients and help with continuity arrangements. That person is bound by confidentiality.
5 How long do we keep information?
The agreed usual periods are: therapy records, where kept, up to seven years after therapy ends; financial records, seven years; and enquiries that do not result in therapy, up to 12 months. Longer retention may be needed for a justified legal, safeguarding, complaints or insurance reason. Individual therapists can explain any different period that applies to their records.
Records are held securely, with access limited to people who need it. They are securely deleted or destroyed when no longer required. Sessions are not recorded or transcribed, and automated or AI-assisted session notes or summaries are not used, unless this has been discussed and agreed in writing beforehand by the therapist and every client taking part in the session. If agreed, your therapist will explain how the resulting information will be used, stored, shared and retained. This is separate from ordinary brief clinical notes.
6 Your rights and concerns
You can ask to see your personal information, correct mistakes, or request restriction or erasure where the law allows. You may also have rights to object, request transfer of eligible information, and withdraw consent where consent is the legal basis. We do not make decisions about your therapy solely by automated processing.
Requests may be subject to legal exceptions, including where records must be kept for a valid reason.
In couples therapy, each person may ask for access to their own personal information. Evolve does not voluntarily provide either partner with joint therapy notes. Any legal information request, including a subject access request or court order, is assessed under the law, taking account of the other person's rights and confidentiality. This means we cannot guarantee that no information will ever need to be disclosed.
To request access to or correction of your information, exercise another data-protection right, or make a privacy complaint about your therapy records, contact your individual therapist using the contact details they have given you. Each therapist is responsible for handling requests and complaints about the information they hold. They may need to confirm your identity before responding.
If you make a data-protection complaint, your therapist will acknowledge it within 30 days, investigate appropriately, keep you informed and explain the outcome without undue delay. For personal information submitted through the Evolve website before a therapist has been assigned, Evolve can help identify the appropriate person responsible for the enquiry.
You may also complain to the Information Commissioner’s Office (ICO): www.ico.org.uk
7 Website, external services and overseas sessions
Our website uses essential cookies and may receive basic technical or usage information. We do not use therapy information for targeted advertising. Website cookies and any optional analytics should be explained through the site's cookie information and controls; you can also manage cookies in your browser.
For therapy delivered through Spill, session notes are entered in Spill's system. Spill's published notice describes Spill and the practitioner as joint controllers for those session notes, retained by Spill for seven years from entry. Spill separately handles platform and booking information. Ask Spill for its current privacy notice (dpo@spill.chat). Other service providers may process information outside the UK; where restricted transfers occur, the required UK safeguards apply. Ask your individual therapist about arrangements relevant to your therapy information.
8 Contact and review
General Evolve enquiries only: info@evolvecounselling.org
For questions about therapy records, data protection, ICO registration, or a data-protection complaint, contact your individual therapist directly. Each therapist is responsible for responding on behalf of their own practice.
Version 3 • Updated Nov 2026 • Couples joint-notes and privacy wording clarified • Review by January 2028 or sooner if law or practice changes
Spill Clients
When our therapists work with Spill, both Spill and Evolve therapists are independently obliged to hold session notes. We are therefore joint controllers with Spill for this purpose. Spill’s Privacy Notice is available here.
Your rights also allow you to lodge a complaint with the Information Commissioner. To find out more visit www.ico.org.uk