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Privacy Policy 2026

 

Last updated 26/10/26

 

Fresh Air And Ltd handles your personal information in accordance with applicable data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This notice explains what information I collect, why I use it, how I store and retain it, when it may be shared, and how you can contact me about it.

 

Who is responsible for your information?

For the purposes of UK data protection law, the data controller is:

Fresh Air And Ltd, United Kingdom
Registered with the Information Commissioner’s Office (ICO)

Contact via the website contact page or hello@freshairand.com

 

What information I collect and why

When you complete the contact form on this website (www.freshairand.com), you may provide personal details such as your name, email address, telephone number and IP address.

 

I collect information you provide through our communications, this agreement, a separate intake form, and our sessions. This may include your contact details and information about your health, wellbeing and circumstances that you choose to share.

 

I use this information to communicate with you, provide and review therapy, keep appropriate records, and meet my professional, legal and insurance responsibilities.

 

Lawful basis for using your information

As part of counselling services, I may process special category personal data, such as health or wellbeing information that you choose to share.

 

Special category data is processed under Article 9(2)(h) UK GDPR (health or social care) and Article 9(3) (professional confidentiality obligations), alongside Article 6(1)(b) (contract).

Explicit consent may be used for optional sharing only.

 

Appropriate safeguards are in place to protect sensitive personal information. Under UK GDPR, personal data is processed on the following lawful bases:

• Consent – where you have actively contacted me or agreed to the processing of your information

• Contractual necessity – where processing is required to take steps prior to or during a counselling or psychotherapy contract

• Legal obligation – where I am required to retain information by law, insurance requirements or professional standards

• Legitimate interests – where I need to run my practice safely and respond to enquiries

 

Forms and storage

I use Google Forms for this agreement, the contract, and for a separate intake form. Anyone with the relevant link may be able to submit a response. Responses are stored in my Google Drive and linked to a Google Sheet. Access is restricted through my Google account’s security settings, and only I can access the account.

 

Please include only the information requested in a form. If you have questions or concerns about sharing information through an online form, contact me before submitting it.

 

Google processes information to provide its services. I use Gmail, and Google Drive. Google maintains data centers around the world, meaning your information can be processed and stored on servers located outside the UK. Google operates under legal transfer mechanisms, such as the UK Extension to the EU-U.S. Data Privacy Framework and Standard Contractual Clauses (SCCs), to legally manage data transfers outside the UK. 

 

Under UK GDPR Guidance from the ICO, making personal data accessible outside the UK is treated as an international transfer, which Google addresses through its Data Processing Addendum and legal frameworks.

 

Confidentiality and supervision

Therapy is confidential. I may discuss aspects of client work in supervision to support safe and ethical practice. Supervisors are bound by confidentiality.

 

In exceptional circumstances, I may need to share the minimum information necessary where required in accordance with legal and ethical responsibilities. This includes safeguarding concerns, suicide risk, serious crime, medical emergencies, or court orders. Only the minimum necessary information will be shared.

 

Clinical Will

I have a clinical will arrangement with trusted professional colleagues who may access the minimum information needed to contact clients if I am seriously incapacitated or die. They are bound by confidentiality and will only access information if necessary.

 

How I protect your information

Electronic information is protected by passwords and the security settings on my accounts. Paper records are kept in a locked cabinet. I take reasonable steps to keep your information secure and confidential.

 

How long I keep your information

I keep your contact details for up to one year after our therapeutic work ends. I keep session notes for up to seven years after our work ends, after which I securely delete or destroy them, in line with insurance, legal and professional requirements.

 

Online sessions

Online sessions take place using Zoom Pro. Zoom may process technical information, such as device or connection data, to provide its service under its own privacy terms. By default, data is encrypted in transit between the participant's device and Zoom’s cloud servers. Zoom

may process technical information such as IP address or device data.
 

I conduct online sessions in a private space where I cannot be overheard. Please choose a private space where you cannot be overheard, if possible.

 

Neither of us may audio or video record a session unless we have expressly agreed to this in advance.

 

Use of artificial intelligence

I do not use artificial intelligence (AI) to record, transcribe, analyse or summarise sessions, prepare client notes, or make decisions about your care. I do not enter your personal information into AI tools. All clinical notes are handwritten.

 

If I consider introducing an AI tool that would process your personal information, I will explain its purpose, how it handles data and the relevant risks, and discuss this with you before using it.

 

Your data protection rights

Depending on the circumstances, you may have the right to request access to your personal information, ask for inaccurate information to be corrected, request erasure or restriction of processing, object to some processing, or request transfer of your information. If I rely on consent for a particular use, you can withdraw that consent. Some rights depend on the lawful basis and may not apply in every situation.

 

To exercise a right or ask a question, contact me using the details above. 

 

Complaints

If you are unhappy with how your personal data is handled, you have the right to complain.

If you make a data protection complaint, please include:

• your name

• what your concern is about

• what you would like me to look into

• how you prefer me to respond

I will acknowledge your complaint within 30 days and investigate it without undue delay.

If you remain dissatisfied, you may escalate your complaint to the ICO.

 

Cookies and IP Addresses – Website only

This website may collect information about your device, including IP address, operating system and browser type, for statistical purposes. This data does not identify you personally.

You can control or disable cookies through your browser settings. Where non-essential cookies are used (such as analytics), a cookie banner will be displayed.

 

This website may contain links to external websites. These websites have their own privacy policies, and Fresh Air And Ltd is not responsible for their content or privacy practices.

 

Contact Form Consent

By submitting an online contact form, you consent to Fresh Air And Ltd storing and processing your personal data in accordance with the Privacy Policy.

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Changes to this notice

If I make a significant change to how I use your personal information, I will update this notice and let you know where appropriate.