Your information

Your privacy matters. This notice explains the confirmed arrangements for enquiries and counselling records.

Who is responsible

Markus Flaherty, trading as Markus Flaherty Counselling, is responsible for your practice information. Contact markusflahertycounselling@gmail.com or 07788 715463 with privacy questions. I am registered with the Information Commissioner’s Office (ICO).

Enquiries

I collect your name, email address and any phone number or message you choose to provide so that I can reply, discuss availability and arrange an introductory consultation. Please keep initial enquiries to contact arrangements and general questions; do not include diagnoses, health information or detailed personal difficulties.

The website form uses Formspree to process and store submissions and forward them to my Gmail inbox. Formspree states that submissions deleted from its dashboard are permanently deleted within 30 days; this does not delete copies already delivered by email. Email sent directly to me is also handled by Google. Phone and text links use your own device’s services. If you do not become a client, I delete enquiry emails and any corresponding Formspree dashboard submissions three months after our last contact. Formspree’s deletion period then applies to deleted submissions.

Counselling records

If we begin counselling, I keep relevant contact details, our working agreement and brief session records to support our work. Records are kept as Word files locally on my encrypted Mac, with an encrypted external-drive backup. These Word records are not synced to iCloud or OneDrive. Enquiry emails are held separately in Gmail.

Client records are retained for at least seven years after the final session, in line with my insurer’s requirements. Longer retention may be necessary where there is an outstanding complaint, claim or legal requirement. Records will be reviewed for secure deletion when retention is no longer necessary; backup copies must also be managed as part of that process.

Confidentiality

Our sessions are confidential. We will discuss the confidentiality agreement before counselling begins. There are exceptions involving certain legal obligations or serious concerns about your safety or someone else’s. Wherever possible, I will discuss any need to share information with you first.

I receive regular professional supervision, where your identity is protected. Information may also need to be shared where required to respond to a complaint, insurance claim or legal process.

Why information is used

Responding to requests about starting counselling and providing agreed sessions involves steps towards, or performance of, our contract. General enquiries and appropriate record retention may involve legitimate interests in running a safe practice and responding to complaints or claims. Where a specific legal duty applies, information may be processed to meet that duty.

For health and other special-category information necessary to provide counselling, I rely on the health or social care condition in Article 9(2)(h) of the UK GDPR, together with Schedule 1, Part 1, paragraph 2 of the Data Protection Act 2018. The information is handled under my legal duty of confidentiality. Where special-category records are necessary to establish, exercise or defend legal claims, Article 9(2)(f) may apply. An insurer’s retention requirement is a contractual requirement; it is not itself a statutory obligation.

Website services and overseas processing

This website is hosted through ChatGPT Sites. Hosting and access services may process technical information such as IP addresses, security logs and account information. I have not added advertising trackers or analytics to the website; this does not mean the hosting service uses no cookies.

OpenAI processes hosted website data under its ChatGPT Sites Data Processing Addendum, which incorporates standard contractual clauses and the UK Addendum for UK data. Sites does not offer a guaranteed UK hosting location. Formspree describes using US infrastructure, and Google describes international processing. Formspree states that it acts as a processor and relies on Standard Contractual Clauses for international transfers. Its published guidance describes EU/EEA arrangements; I am seeking confirmation of the provisions applicable to UK submissions. My Gmail account is governed by Google’s consumer terms and privacy policy. You can contact me for further information about these arrangements.

Provider information: Formspree privacy policy, Google privacy policy, and OpenAI privacy policy.

Your rights

Depending on the circumstances, you can request access to your information, correction, deletion, restriction or transfer, and object to certain uses. These rights have limits: for example, deletion may not be appropriate where records are needed to meet a legal obligation or defend a claim. Contact me using the details above to make a request.

You can also raise a concern with the Information Commissioner’s Office.

Last updated 15 October 2026.