Sarah Higgins Therapy Privacy Policy
Sarah Higgins Therapy Privacy Notice
Last updated: August 2026
1. Who I am
Sarah Higgins Therapy
(Address withheld)
Email: sarahhigginstherapy@gmail.com
Website: https://www.sarahhigginstherapy.co.uk
I am the data controller for the personal information I collect and process in connection with the psychotherapy and counselling services I provide.
I work within the BACP Ethical Framework for the Counselling Professions and comply with the Data Protection (Jersey) Law 2018.
2. What information I collect
I may collect and process the following information:
• Name
• Address
• Telephone number
• Email address
• Date of birth
• GP details
• Emergency contact details
• Information relevant to your therapy, including personal history, relationship information, and mental health information
• Assessment questionnaires (such as GAD-7 and PHQ-9 where used)
• Appointment, payment, and invoicing records
I aim to collect only the information necessary to provide a safe, ethical, and effective therapy service.
3. How I collect your information
Information is usually obtained:
• when you contact me to enquire about therapy,
• through the personal details form and assessment process,
• during therapy sessions,
• through email, telephone, text message, or online meeting platforms where these are used for therapy administration or sessions.
4. Why I process your information
I process your information for the following purposes:
• providing psychotherapy and counselling,
• arranging and managing appointments,
• maintaining clinical records,
• invoicing and accounting,
• communicating with you about the therapy service,
• fulfilling professional, legal, ethical, safeguarding, and insurance obligations.
5. Lawful basis for processing
Under the Data Protection (Jersey) Law 2018, the lawful bases I rely on include:
• Performance of a contract – to provide the therapy service you have requested.
• Legal obligation – where I am required to comply with legal or regulatory duties.
• Vital interests – where processing is necessary to protect life or prevent serious harm.
• Legitimate interests – in running and safeguarding my professional practice appropriately.
Because psychotherapy involves sensitive health-related information, I process special category personal data where this is necessary for the provision of counselling and psychotherapy services, for safeguarding purposes, and in accordance with my professional confidentiality and ethical obligations. Information relating to communication with your GP is processed as part of the therapeutic service and duty-of-care arrangements described in this Privacy Notice and the Psychotherapy Service Agreement.
6. Confidentiality and sharing information
Everything discussed in therapy is treated as confidential.
Information will not normally be shared with third parties except where:
• there is a serious risk of harm to you or another person,
• there are safeguarding concerns relating to a child or vulnerable adult,
• disclosure is required by law or court order,
• there is another overriding professional or legal obligation relating to safeguarding or the prevention of serious crime.
Wherever possible, I will aim to discuss any proposed disclosure with you before sharing information, unless doing so would increase risk or prevent appropriate safeguarding action.
Contact with your GP
As part of my professional therapeutic practice and duty of care, clients are required to provide their GP details before therapy begins. At the commencement of therapy, I will normally write to your GP to inform them that you have begun psychotherapy with me. Where relevant, this communication may include information obtained during the assessment process, such as the scores from the GAD-7 and PHQ-9 questionnaires.
The purpose of this contact is to support safe and coordinated care, ensure that relevant healthcare professionals are aware that you are receiving psychotherapy, and assist with appropriate clinical communication where necessary.
During the course of therapy, I may also contact your GP or another appropriate healthcare professional if I believe it is necessary to share information relevant to your mental health, physical health, wellbeing, or safety. Wherever possible, I will aim to discuss any additional information sharing with you beforehand, unless doing so would increase risk or prevent appropriate safeguarding action.
By proceeding with therapy and signing the service agreement, you confirm that you understand and agree to this arrangement as part of the conditions under which the psychotherapy service is offered.
7. Clinical notes
I keep minimal, password-protected clinical notes that are intended to support continuity of care and professional accountability. Notes are factual, concise, and limited to information relevant to the therapeutic work.
Where possible, identifying details are minimised within clinical notes.
8. How your information is stored
Your information is stored securely using a combination of encrypted electronic systems and, where applicable, locked physical storage.
I take reasonable technical and organisational measures to protect personal information from unauthorised access, loss, misuse, or disclosure.
Administrative systems such as email, calendar, invoicing software, secure digital note storage, Zoom, Microsoft Teams, or telephone services may be used to support the practice.
I do not input identifiable client information into generative AI systems.
9. How long I keep your information
Clinical records are retained for a period consistent with professional, legal, and insurance requirements, currently five years after the end of therapy, unless a longer retention period is required.
Financial and accounting records may be retained for longer where required by tax or accounting legislation.
At the end of the retention period, records will be securely destroyed or permanently deleted.
10. Your rights
Under the Data Protection (Jersey) Law 2018, you have rights including:
• the right to access your personal information,
• the right to request correction of inaccurate information,
• the right to request erasure in certain circumstances,
• the right to request restriction of processing in certain circumstances,
• the right to object to certain types of processing,
• the right to request transfer of information where applicable.
To exercise any of these rights, please contact:
sarahhigginstherapy@gmail.com
I will normally respond within one month.
Please note that some rights may be limited where information forms part of confidential therapy records and exemptions apply under data protection law.
11. Complaints
If you have any concerns about how I use your personal information, please contact me in the first instance:
sarahhigginstherapy@gmail.com
You also have the right to complain to the Jersey Office of the Information Commissioner (JOIC):
Jersey Office of the Information Commissioner
2nd Floor, 5 Castle Street
St Helier
Jersey JE2 3BT
Website: https://jerseyoic.org
Email: enquiries@jerseyoic.org
12. Changes to this notice
I may update this Privacy Notice from time to time to reflect changes in legal requirements, professional guidance, or the way my practice operates. The most current version will be available on my website and can be provided on request.