Privacy Policy

Last updated: 17 August 2026

I am Josephine Tsotetsi-Kearns, trading as Josie Therapy, a Humanistic Counsellor based in Hove. I am committed to protecting your privacy and handling your personal information in a safe, confidential, transparent and lawful way.

This Privacy Policy explains how I collect, use, store and protect personal information when you visit my website, contact me, make an enquiry or use my counselling services.

For the purposes of UK data protection law, Josephine Tsotetsi-Kearns, trading as Josie Therapy, is the data controller responsible for the personal information described in this policy.

Who I Am

Business name: Josie Therapy
Owner: Josephine Tsotetsi-Kearns
Professional registration: Registered Member of the British Association for Counselling and Psychotherapy (MBACP)
Practice address: Hove Therapy Rooms, 69 Church Road, Hove, BN2 2BB
Email: enquiries@josietherapy.co.uk
Telephone: 07983 800620

What Personal Information I Collect

I only collect personal information that is reasonably necessary to respond to enquiries, manage my counselling practice and provide counselling services.

Depending on your relationship with me, this may include:

• your name;

• email address;

• telephone number;

• address where appropriate;

• date of birth or age where relevant;

• emergency contact information where appropriate;

• appointment information;

• information you provide when making an enquiry;

• correspondence between us;

• information relevant to counselling and our therapeutic work;

• counselling notes and records;

• payment and transaction information; and

• information required to meet professional, safeguarding, legal or regulatory responsibilities.

I may receive information directly from you or, where appropriate, from a parent, guardian or another person involved in arranging support.

Special Category Information

Because of the nature of counselling, the information you choose to share with me may include particularly sensitive personal information.

This may include information about your:

• physical or mental health;

• emotional wellbeing;

• relationships and family circumstances;

• racial or ethnic origin;

• religious or philosophical beliefs;

• sexual orientation or sex life; or

• other sensitive aspects of your experiences or circumstances.

Some of this information is classed as special category personal data under UK data protection law and receives additional legal protection.

I process special category information only where I have both an appropriate lawful basis and an applicable condition for processing it under UK data protection law.

Children and Young People

I specialise in working with children and young people, as well as with people of all ages.

Where counselling involves a child or young person, I may process information relating to them and, where appropriate, information relating to a parent, guardian or another person involved in their care.

The information collected and how it is used will depend on the child or young person's age, understanding and individual circumstances, the arrangements for counselling and any applicable safeguarding responsibilities.

I aim to respect the privacy and confidentiality of children and young people while meeting my professional, ethical, legal and safeguarding responsibilities.

Contact Forms and Enquiries

If you contact me through my website, by email or by telephone, I may collect personal information, including your name, email address, telephone number and any information you choose to include in your enquiry.

I use this information to respond to your enquiry, discuss whether counselling may be suitable and, where appropriate, arrange an initial consultation or counselling session.

Please avoid including unnecessary sensitive or confidential information in a general website enquiry. More detailed personal information can be discussed appropriately if we decide to work together.

Information Collected Through My Website

When you visit my website, certain technical information may be collected automatically or after you have made the appropriate cookie choice.

Depending on the technologies involved and your choices, this may include:

• IP address;

• browser and device information;

• pages visited;

• date and time of visits;

• time spent on pages;

• website interactions;

• referring website or search engine;

• approximate geographic information; and

• cookie and usage information.

This information may be used to maintain website security, understand website performance and improve visitors' experience.

Cookies, Analytics and Marketing Technologies

My website uses cookies and similar technologies. Services currently used on the website include Google Analytics, Google Tag Manager, Google Maps and Meta Pixel.

Google Analytics helps me understand how visitors use my website, including which pages they visit and how they interact with the site.

Google Tag Manager helps me manage website tags and technologies.

Google Maps provides location and map functionality.

Meta Pixel may be used to measure website interactions, advertising performance and the effectiveness of marketing campaigns.

Where consent is required, optional analytics and marketing technologies will only be activated after you have made the appropriate choice through my cookie controls. I do not intentionally provide advertising platforms with the contents of counselling sessions or detailed information about your therapeutic concerns. More information about these technologies and your choices is available in my Cookie Policy.

How I Use Your Personal Information

I may use your personal information to:

• respond to counselling enquiries;

• communicate with you;

• arrange and manage appointments;

• provide counselling services;

• maintain appropriate counselling records;

• administer my counselling practice;

• manage payments and financial records where applicable;

• meet my professional and ethical responsibilities;

• fulfil safeguarding responsibilities;

• comply with legal or regulatory requirements;

• establish, exercise or defend legal claims where necessary;

• maintain the security and operation of my website;

• understand and improve my website; and

• measure marketing activity where you have provided the appropriate consent.

I do not sell, rent or trade your personal information.

Lawful Bases for Processing

Under UK data protection law, I must have a lawful basis for processing personal information.

Depending on the purpose and circumstances, I may rely on:

Contract: where processing is necessary to provide counselling services or take steps at your request before counselling begins.

Legitimate interests: where processing is reasonably necessary to operate, administer and protect my counselling practice, respond to enquiries or maintain my website, provided those interests do not override your rights and interests.

Legal obligation: where processing is necessary for me to comply with a legal obligation.

Consent: where I ask you to make a genuine choice about a particular use of your information, including certain optional website technologies.

Vital interests: in exceptional circumstances, where processing is necessary to protect someone's life.

The lawful basis used will depend on the particular reason the information is being processed.

Special Category Data and Health Information

Where I process special category personal data, including information concerning physical or mental health, I must also have an appropriate condition for processing that information under Article 9 of the UK GDPR.

Depending on the processing involved, an applicable condition may include processing necessary for the provision or management of health or social care by a professional subject to appropriate confidentiality obligations, or another condition permitted by UK data protection law.

Confidentiality

Confidentiality is an important part of counselling.

I am a registered member of the British Association for Counselling and Psychotherapy (BACP) and work within its ethical framework.

Information shared during counselling is treated confidentially. However, confidentiality is not absolute.

There are limited circumstances where I may need to share information, including where:

• there is a serious risk of harm to you or another person;

• there is a safeguarding concern;

• disclosure is required by law; or

• another applicable legal or professional obligation requires disclosure.

Wherever reasonably possible and appropriate, I will aim to discuss this with you first.

Professional Supervision

As part of safe and ethical counselling practice, aspects of therapeutic work may be discussed confidentially with my professional supervisor.

Supervision supports safe, ethical and reflective practice.

My supervisor is also bound by professional confidentiality, and I take appropriate steps to protect client privacy when therapeutic work is discussed.

Who I May Share Personal Information With

I do not sell personal information or share it unnecessarily.

Where necessary and appropriate, personal information may be processed by or shared with:

• my professional supervisor;

• website and hosting providers;

• email and communication providers;

• payment or accounting providers where applicable;

• IT and technical service providers;

• professional advisers;

• insurers where appropriate;

• safeguarding or healthcare professionals where necessary;

• emergency services where necessary;

• courts, regulators or public authorities where legally required; and

• Google, Meta or other technology providers where their services are enabled and legally permitted.

I aim to limit any disclosure to the information reasonably necessary for the relevant purpose.

How I Store and Protect Your Information

I take appropriate technical and organisational measures to protect personal information from accidental loss, unauthorised access, misuse, alteration or disclosure.

Physical records are stored securely.

Electronic information is password-protected and stored securely where appropriate.

I aim to minimise identifying information contained within counselling notes where appropriate and handle records in accordance with my professional and data protection responsibilities.

While I take reasonable precautions, no method of electronic storage or internet transmission can be guaranteed to be completely secure.

How Long I Keep Your Information

I only retain personal information for as long as reasonably necessary for the purposes for which it was collected and to meet relevant professional, legal, insurance, financial or regulatory requirements.

Counselling notes are currently retained for five years after the end of therapy and are then securely deleted or destroyed.

Other information may be retained for different periods depending on its purpose.

For example, financial and transaction records may need to be retained for the period required by applicable tax or accounting requirements.

Information relating to an initial enquiry that does not lead to counselling may be retained for a shorter period where there is no continuing reason to keep it.

International Data Transfers

Some third-party technology providers used by my website or counselling practice may process personal information outside the United Kingdom.

Where personal information is transferred internationally, I will take appropriate steps to ensure the transfer complies with applicable UK data protection requirements.

This may include transfers covered by UK adequacy regulations or the use of appropriate contractual safeguards where required.

Your Data Protection Rights

Depending on the circumstances, UK data protection law gives you rights regarding your personal information.

These may include:

• the right to be informed about how your information is used;

• the right to request access to personal information held about you;

• the right to request correction of inaccurate or incomplete information;

• the right to request deletion of your information in certain circumstances;

• the right to request restriction of processing in certain circumstances;

• the right to object to certain processing;

• the right to data portability in certain circumstances;

• the right to withdraw consent where processing is based on consent; and

• rights relating to certain automated decision-making and profiling.

These rights are not absolute. Whether a particular right applies will depend on the circumstances and the legal basis for processing.

You will not normally be required to pay a fee to exercise your data protection rights.

Withdrawing Consent

Where I rely on your consent to process personal information, you can withdraw that consent at any time. Withdrawing consent does not affect the lawfulness of processing carried out before consent was withdrawn.

For website cookies and similar technologies, you can change your choices through the Cookie Settings available on my website.

Automated Decision-Making and Profiling

I do not use solely automated decision-making to decide whether you can receive counselling from me.

Website analytics and advertising technologies may perform certain forms of measurement, audience creation or profiling where enabled.

Where these technologies require consent, they are subject to the choices available through my cookie controls.

Personal Data Breaches

I take the security of personal information seriously.

If a personal data breach occurs, I will assess its nature and potential impact and take appropriate action.

Where required by data protection law, I will notify the Information Commissioner's Office (ICO) and/or affected individuals.

Data Protection Complaints

If you have a concern or complaint about how I have collected, used, stored or protected your personal information, please contact me using the details below.

I will take appropriate steps to acknowledge, investigate and respond to data protection complaints in accordance with applicable UK data protection requirements.

You also have the right to raise a concern with the Information Commissioner's Office (ICO), the UK's independent regulator for data protection.

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

Links to Other Websites

My website may contain links to websites or services operated by other organisations. I am not responsible for the privacy practices, security or content of third-party websites. I recommend reviewing the privacy information provided by any third-party website or service you choose to use.

Changes to This Privacy Policy

I may update this Privacy Policy from time to time to reflect changes to my counselling practice, website, technology providers or legal requirements.

If I introduce new website functionality or third-party services in the future, such as an online booking system, I may update this Privacy Policy to explain how personal information is processed in connection with those services.

Any changes will be published on this page, and the last updated date will be changed accordingly.

Contact Me

If you have questions about this Privacy Policy, would like to exercise a data protection right or wish to make a data protection complaint, please contact:

Josephine Tsotetsi-Kearns trading as Josie Therapy
Hove Therapy Rooms
67 Church Road
Hove
BN2 2BB

Email: enquiries@josietherapy.co.uk
Telephone: 07983 800620