Open Hands Counselling Centre
Operated by Gifty Ogene
Last updated: 12 October 2026

1. Introduction

At Open Hands Counselling Centre, your privacy, confidentiality and trust are important to me.

I am committed to protecting the personal information you share when making an enquiry, accessing counselling or clinical supervision, attending training or workshops, or using this website.

This Privacy Policy explains what personal information I collect, why it is needed, how it is used and protected, how long it is retained, and your rights under data protection legislation.

Open Hands Counselling Centre is operated by Gifty Ogene, who is responsible for determining how personal information is used in connection with the practice.

Personal information is handled in accordance with applicable UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Open Hands Counselling Centre provides counselling services to adults aged 18 and over.

Contact for privacy enquiries

Gifty Ogene
Open Hands Counselling Centre
Website: https://openhandscounsellingcentre.com
Email: info@openhandscounsellingcentre.com

2. Information I Collect

Depending on the services you enquire about or receive, I may collect and process:

• Personal and contact information:Name, date of birth, address, telephone number, email address and preferred communication method.
• Enquiry and booking information:Details of your enquiry, appointment history, session arrangements and relevant correspondence.
• Assessment and counselling information:Presenting concerns, relevant personal history, assessment information, therapeutic goals and clinical notes.
• Health and wellbeing information:Information relevant to your emotional or psychological wellbeing, including appropriate assessment and outcome measures.
• Emergency and safeguarding information:Emergency contact details, GP information and relevant safeguarding or risk information where necessary.
• Payment and administrative information:Invoices, payment status, transaction records and relevant financial correspondence.
• Clinical supervision information:Information required to provide supervision and maintain appropriate professional records.
• Training and workshop information:Registration, attendance and communication details where applicable.
• Website information:Technical information collected through website functionality, security measures and any cookies or analytics tools in use.

I aim to collect only information that is relevant and necessary for the services provided.

3. How Your Information Is Used

Your personal information may be used to:

• Respond to enquiries and communicate about services.
• Arrange, manage and provide counselling or clinical supervision.
• Carry out assessments and maintain appropriate professional records.
• Manage appointments, cancellations, invoices and payments.
• Monitor therapeutic progress using appropriate assessment measures.
• Maintain professional standards and obtain clinical supervision.
• Fulfil safeguarding and risk-management responsibilities.
• Meet applicable legal, insurance and professional obligations.
• Respond to concerns, complaints or requests relating to personal information.
• Administer training, workshops and other services you have requested.
• Maintain the security and effective operation of the practice and website.

Your personal information is not sold to advertisers.

Personal information is not used for unrelated marketing without an appropriate lawful basis and any consent required by law.

4. Legal Basis for Processing Personal Information

Open Hands Counselling Centre processes personal information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

The lawful basis for processing personal information depends on the purpose for which it is collected and used.

The relevant lawful bases under Article 6 of the UK GDPR include:

Performance of a contract – Article 6(1)(b)

Where processing is necessary to arrange and provide counselling, clinical supervision or other services requested by clients, including associated administration.

Legal obligations – Article 6(1)(c)

Where processing is necessary to comply with applicable legal requirements.

Legitimate interests – Article 6(1)(f)

Where processing is necessary for the legitimate administration, security and professional management of the practice, provided these interests are not overridden by the individual’s rights and freedoms.

Consent – Article 6(1)(a)

Where consent is the appropriate lawful basis for specific activities, such as optional communications or other processing requiring consent.

Sensitive Personal Information

Counselling may involve collecting and processing sensitive personal information, including information about mental health, emotional wellbeing, personal experiences and relevant medical history.

Such information may constitute special-category personal data under the UK GDPR and requires an additional lawful condition for processing.

For sensitive information processed where necessary to provide counselling and therapeutic care, Open Hands Counselling Centre relies on Article 9(2)(h) of the UK GDPR, together with the relevant provisions of the Data Protection Act 2018, Schedule 1, Part 1, paragraph 2, concerning health or social care purposes.

This processing is carried out within the professional confidentiality obligations applicable to the practice, including those reflected in the counselling agreements and the ethical standards of the National Counselling and Psychotherapy Society (NCPS).

Where other circumstances require the processing or disclosure of sensitive information, such as safeguarding or legal obligations, an appropriate lawful basis and additional condition will be considered in accordance with applicable legislation.

Personal information is processed only where necessary and appropriate for the relevant purpose.

5. Sessionly and Practice Management

Open Hands Counselling Centre uses Sessionly as a practice-management system.

Depending on the features configured, Sessionly may be used to manage:

• Client enquiries and contact information.
• Appointments and booking arrangements.
• Counselling agreements and electronic signatures.
• Client records and relevant clinical documentation.
• Invoices and payment administration.
• Assessment forms and outcome measures.
• Administrative communications and reminders.

Access to personal information is managed according to professional and administrative requirements.

Sessionly’s handling of personal information is also subject to its applicable privacy, security and data-processing arrangements.

Other service providers may be used for payment processing, email, website hosting or other essential practice functions. Where necessary, relevant personal information may be processed by those providers to deliver the service.

6. Confidentiality and Clinical Supervision

Counselling and clinical supervision information is treated confidentially, subject to professional, safeguarding and legal limits.

As part of maintaining professional standards, I receive regular clinical supervision.

Relevant aspects of therapeutic work may be discussed in supervision, with identifying information omitted wherever practicable. Clinical supervisors are also expected to maintain professional confidentiality.

There may be circumstances where information needs to be shared, including where:

• There is a serious concern about someone’s safety.
• An adult at risk requires safeguarding intervention.
• Disclosure is required by law or a valid legal process.
• Another applicable legal basis permits or requires disclosure.

Where appropriate and safe, I will aim to discuss a proposed disclosure with you beforehand.

Any disclosure will be limited to information reasonably necessary for the relevant purpose.

7. Couples Counselling and Individual Privacy

Couples counselling may involve information relating to both partners and their relationship.

Each partner’s privacy and confidentiality will be respected.

Requests for access to counselling records will be considered in accordance with applicable data protection law, taking account of each person’s rights and the confidentiality of the other partner.

One partner is not automatically entitled to receive all confidential information relating to the other.

Information shared privately by one partner will be handled in accordance with the confidentiality arrangements explained in the Couples Counselling Agreement, including relevant legal and safeguarding exceptions.

8. Artificial Intelligence (AI)

Open Hands Counselling Centre may use artificial intelligence (AI) tools for limited administrative and professional purposes, including developing general educational resources, preparing workshop materials and improving the grammar, clarity, structure and professional presentation of non-confidential written materials.

AI is not currently used to record, transcribe or generate client clinical notes.

Clinical observations, assessments, therapeutic decisions, safeguarding decisions and professional judgements remain my responsibility as the practitioner. AI does not replace the therapeutic relationship or my professional expertise.

Identifiable or confidential client information is not submitted to general-purpose AI tools for clinical decision-making or routine note-writing.

If AI-assisted clinical documentation is introduced in the future, its suitability, confidentiality arrangements, data protection requirements and any necessary client information or consent arrangements will be reviewed before implementation.

Clients are welcome to ask questions about how AI is used within the practice.

9. Sharing Information With Third Parties

Personal information may be shared with appropriate service providers where necessary to operate the practice, including practice-management, payment-processing, communication and website-hosting providers.

Information may also be shared where necessary and lawful with relevant healthcare professionals, emergency services, safeguarding agencies, legal authorities or other appropriate organisations.

Where services are provided through an employer, insurer or Employee Assistance Programme (EAP), any information shared with the commissioning organisation will be governed by the applicable service arrangements, confidentiality obligations and data protection requirements.

Confidential clinical information will not routinely be shared with an employer, insurer or commissioning organisation merely because they are paying for counselling.

Where personal information is shared, I aim to limit the disclosure to what is necessary and appropriate.

10. International Data Transfers

Some clients may access services from outside the United Kingdom.

Certain technology or payment providers may also process or store information outside the UK.

Where personal information is transferred internationally, I will take steps to ensure that any required legal safeguards are in place, in accordance with applicable UK data protection legislation.

Further information about relevant international transfers and safeguards may be requested using the practice contact details.

11. Record Retention

Personal information is retained only for as long as reasonably necessary, taking account of applicable legal, professional, safeguarding and insurance requirements.

Counselling records are generally retained for six years following the end of counselling, unless a longer or different period is required or justified.

This retention period reflects the practice’s record-keeping arrangements and takes account of professional responsibilities and insurance requirements.

Records involving safeguarding matters, complaints, legal proceedings or other exceptional circumstances may require different retention arrangements.

Administrative, enquiry and financial records may have different appropriate retention periods.

When information is no longer required, it will be securely deleted, anonymised or disposed of, subject to applicable legal and professional obligations.

12. Information Security

I take reasonable and appropriate steps to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

These measures include using appropriate practice-management and communication systems, limiting access to information and maintaining professional confidentiality.

No electronic communication or storage system can be guaranteed to be completely risk-free.

If a personal data breach occurs, it will be assessed and managed in accordance with applicable data protection requirements, including any necessary notifications.

13. Your Data Protection Rights

Depending on the circumstances and applicable legal conditions, you may have the right to:

• Request access to personal information held about you.
• Request correction of inaccurate or incomplete information.
• Request deletion of information in certain circumstances.
• Request restriction of certain types of processing.
• Object to certain uses of your information.
• Request data portability where applicable.
• Withdraw consent where processing is based on consent.

These rights are not absolute and may be subject to relevant legal exemptions, including confidentiality and third-party privacy considerations.

You may contact Open Hands Counselling Centre using the practice contact details to make a data protection request or raise a concern.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s independent data protection regulator.

Further information is available at:

https://ico.org.uk

14. Website Cookies and Analytics

The Open Hands Counselling Centre website may use cookies or similar technologies to support essential website functions, security and performance.

If optional analytics or other non-essential technologies are used, visitors will be provided with appropriate information and consent choices where required by law.

The website’s cookie information should explain which technologies are used, their purposes, relevant providers and retention periods.

Non-essential cookies or similar technologies requiring consent will not be activated before valid consent has been obtained.

Visitors should be able to manage their preferences through the website’s cookie controls where applicable.

15. Changes to This Privacy Policy

This Privacy Policy may be reviewed and updated to reflect changes in legislation, professional requirements, practice arrangements or the technology used to deliver services.

The latest version will be made available on the Open Hands Counselling Centre website.

Where changes materially affect how personal information is processed, appropriate steps will be taken to inform affected individuals where required.

16. Contact and Further Information

If you have questions about this Privacy Policy, how your information is handled or your data protection rights, please contact:

Gifty Ogene
Open Hands Counselling Centre
Website: https://openhandscounsellingcentre.com
Email: info@openhandscounsellingcentre.com

I welcome questions and will take privacy concerns seriously and handle them respectfully and professionally.