Privacy Notice

Last Updated: 19th June 2026

1. Who I Am

This Privacy Notice explains how Perception Check Ltd collects, uses, stores and protects your personal information.

Perception Check Ltd is the Data Controller for the personal information you provide.

Callum Armstrong
Counsellor and Director, Perception Check Ltd

ICO Registration Number: ZB728110

If you have any questions about how your information is handled or wish to exercise your data protection rights, please contact me using the details above.

2. What Personal Data I Collect

In order to provide counselling services, I may collect and process the following information:

Contact and Identity Information

Name
Date of birth
Address
Telephone number
Email address
Emergency contact details
GP details (where appropriate)

Counselling and Health Information

Presenting issues and reasons for seeking counselling
Relevant medical history
Mental health history
Information relating to your circumstances, relationships and background
Risk assessments where appropriate
Session notes and clinical records

Administrative Information

Appointment records
Invoices and payment information
Correspondence between us

Website Enquiries

If you contact me through my website, I may collect:

Your name
Email address
Telephone number
The content of your enquiry

Counselling records and health-related information are classified as special category personal data under Article 9 UK GDPR and receive additional legal protection.

3. How I Collect Your Information

I collect information directly from you:

When you contact me by telephone, email or website enquiry form
During the initial assessment process
During counselling sessions
Through correspondence between us

I do not normally obtain information about you from third parties unless:

You have provided explicit permission;
You are referred through an Employee Assistance Programme (EAP), insurer or similar service; or
Disclosure is required for safeguarding or legal reasons.

4. Why I Process Your Information

I process personal information for the following purposes:

Providing counselling services
Maintaining counselling records
Managing appointments and communication
Assessing and managing risk
Meeting professional, ethical and legal obligations
Managing invoices and payments
Responding to enquiries
Managing and improving my practice

I do not sell or trade personal information.

5. Lawful Basis for Processing

General Personal Data

Under Article 6(1)(b) UK GDPR, processing is necessary for the performance of the counselling agreement between us.

Special Category Health Data

Under Article 9(2)(h) UK GDPR, processing is necessary for the provision of health or social care by a professional subject to a duty of confidentiality.

The relevant condition under the Data Protection Act 2018 is Schedule 1, Part 1, Paragraph 2 (Health or Social Care Purposes).

As a BACP-registered counsellor, I am bound by professional obligations of confidentiality and ethical practice.

6. Professional Supervision

The British Association for Counselling and Psychotherapy (BACP) requires counsellors to engage in regular clinical supervision.

Supervision helps ensure that clients receive safe, ethical and effective counselling.

When discussing client work in supervision:

Identifying information is removed wherever possible
Names and contact details are not disclosed
Discussions focus on the therapeutic work rather than personal identification
Supervisors are bound by professional confidentiality obligations

7. Clinical Trustee Arrangement

In the event of my death, serious illness or incapacity, I have appointed a trusted clinical trustee who is also a qualified counsellor and bound by professional confidentiality obligations.

The trustee may access client records solely for the purpose of:

Informing clients of the situation
Arranging secure transfer of records where appropriate
Managing the safe closure of the practice
Ensuring records are retained or destroyed in accordance with legal requirements

The trustee will not access counselling content unless it is necessary to carry out these responsibilities.

8. Who I May Share Information With

Your information is treated confidentially and will only be shared where necessary.

Professional Supervisor

Anonymous or pseudonymised information may be discussed during supervision.

Accountant

Limited financial information such as invoice records may be shared for accounting and tax purposes.

Employee Assistance Programmes or Insurers

Where counselling is funded through a third party, limited information may be shared in accordance with the arrangement and with your knowledge.

IT Providers

Technical service providers may have incidental access to systems when carrying out maintenance or support.

Legal or Safeguarding Authorities

Information may be disclosed where required by law or where necessary to protect individuals from serious harm.

9. Confidentiality and Its Limits

Everything discussed in counselling is confidential unless there is a legal or ethical reason requiring disclosure.

Examples include:

Serious Risk of Harm

Where there is a serious and immediate risk to your safety or the safety of another person.

Safeguarding

Where concerns arise regarding a child or vulnerable adult.

Legal Requirements

Where disclosure is required by law, court order, or statutory obligation.

Serious Crime

Where disclosure may be required in relation to terrorism, money laundering, human trafficking or other serious criminal activity.

Where possible, I will discuss any intended disclosure with you first unless doing so would increase risk or be unlawful.

Only the minimum necessary information will be disclosed.

10. How Your Information Is Protected

I take reasonable and proportionate steps to protect personal information.

Security measures include:

Password-protected devices
Encrypted electronic systems where appropriate
Secure cloud-based services
Restricted access to client records
Locked storage for paper records
Secure destruction procedures
Regular review of security arrangements

11. International Data Transfers

Some service providers used by Perception Check Ltd may process information outside the United Kingdom.

Where this occurs, appropriate safeguards are used in accordance with Chapter V of the UK GDPR, including:

Adequacy regulations;
The UK Extension to the EU-US Data Privacy Framework (where applicable);
International Data Transfer Agreements (IDTAs);
Standard Contractual Clauses (SCCs).

Further information can be provided on request.

12. How Long Information Is Retained

Counselling Records

Counselling records are normally retained for seven years following the end of therapy.

Financial Records

Financial records are retained for six years in accordance with HMRC requirements.

Website Enquiries

Enquiries that do not result in counselling services are normally deleted after twelve months.

At the end of the retention period, records are securely destroyed or permanently deleted.

13. Your Rights

Under UK GDPR you have the right to:

Be informed about how your information is used
Access your personal information
Request correction of inaccurate information
Request erasure in certain circumstances
Restrict processing in certain circumstances
Object to certain types of processing
Request data portability where applicable
Challenge decisions made solely by automated processing

Requests can be made by contacting: support@perceptioncheck.co.uk

I will normally respond within one month.

14. Automated Decision-Making

I do not use automated decision-making or profiling in relation to counselling services.

15. Complaints

If you have concerns about how your personal information has been handled, please contact me first so that I have an opportunity to address the issue.

Email: support@perceptioncheck.co.uk

If you remain dissatisfied, you have the right to complain to the Information Commissioner's Office (ICO).

Information Commissioner's Office

Website: ico.org.uk

Telephone: 0303 123 1113

Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

If your concern relates to professional conduct, you may also contact the British Association for Counselling and Psychotherapy (BACP).

16. Third-Party Websites

My website and social media pages may contain links to external websites.

I am not responsible for the privacy practices, content or security of external websites and encourage you to review their privacy notices separately.

17. Changes to This Privacy Notice

This Privacy Notice is reviewed regularly and may be updated from time to time.

The latest version will always be available on my website and can be provided on request.

Perception Check Ltd
ICO Registration Number: ZB728110

Privacy Notice

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