Last updated: 01/07/2026
The Listening Centre (“we”, “us”, “our”) is committed to protecting your privacy. This policy explains what personal information we collect, why, how we use it, and your rights in relation to it — including your right to complain if you think we’ve got it wrong.
This policy applies to visitors to our website (www.thelisteningcentre.co.uk), clients referred to us for counselling or related services, HR contacts at organisations we work with, and our affiliate counsellors.
We are a “data controller” for the purposes of the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Data (Use and Access) Act 2025.
1. Who we are
The Listening Centre, Energy House, 35 Lombard Street, Lichfield, Staffordshire, WS13 6DP.
Data Protection contact: Sharon McCormick, reachable at enquiry@thelisteningcentre.co.uk.
2. What information we collect
From website visitors and enquirers:
- Name and contact details (email, phone)
- Job title and organisation, where relevant (e.g. HR contacts making a referral)
- Details you provide in an enquiry or contact form
- Standard website usage data (see our Cookie Policy)
From clients referred for counselling, mediation, or related services:
- Contact and demographic details necessary to deliver the service
Special category data, including information about your physical and mental health, and in some cases sexual orientation, religious belief, or information relating to criminal offences (for example, in cases involving domestic abuse or safeguarding disclosures)
- Clinical notes and session records made by your counsellor
- Outcome and assessment data used to monitor and report on service effectiveness (in anonymised or aggregated form to commissioning organisations)
From affiliate counsellors:
- Qualification and accreditation details, professional indemnity insurance information, DBS status, and case-related records
We only collect what is necessary for the purpose in question. We do not collect more than we need.
3. Our lawful basis for processing
Ordinary personal data (name, contact details, enquiry content): processed on the basis of legitimate interests — responding to your enquiry, administering our services — or consent, where you have actively opted in (e.g. to a mailing list).
Special category data (health, clinical, and related information): processed on the basis of:
- Explicit consent — for clients accessing counselling directly, or
- Article 9(2)(h) — the provision of health or social care treatment, where the service is delivered under a contract with a health professional or equivalent person subject to a duty of confidentiality (this applies to the therapeutic relationship itself)
Where we process data relating to criminal offences (for example, information disclosed during a safeguarding or domestic abuse conversation), we do so only where necessary, and in line with our safeguarding policy, under the conditions set out in Schedule 1 of the Data Protection Act 2018.
We will always tell you, at the point of referral or first session, what we are collecting and why.
4. What we do with your information
- To provide the service you’ve been referred for or have requested (counselling, mediation, training, clinical supervision)
- To maintain accurate clinical and case records, as required by our professional and insurance obligations
- Internal record-keeping and invoicing
- To report anonymised or aggregated outcome data to the organisation that referred you (we do not share identifiable clinical content with employers or commissioners without your explicit consent, except where a legal or safeguarding duty requires it)
- To improve our services
- To send you information about events or services we think may interest you, where you’ve consented to this
We will not use your data for any purpose incompatible with the one it was collected for, without telling you first.
5. How long we keep your information
- Clinical and case records: retained for 7- years from the end of treatment, in line with professional ethical guidance and our professional indemnity insurer’s requirements
- Enquiry and website contact data: retained for 7 years, or until you ask us to delete it
- Affiliate and contractual records: retained for 7 years after the end of the working relationship, for tax and insurance purposes
6. Who we share your information with
We will not sell, rent, or share your personal information with third parties for marketing purposes.
We may share information:
- With your explicit consent
- Where required by law (for example, a court order, or a statutory safeguarding duty)
- With regulatory or professional bodies (BACP, CPCAB) where a complaint is being investigated
- With IT and portal service providers who process data on our behalf, under a written data processing agreement
We use a UK-based client portal to manage case data. Support and development of this portal is provided by a contractor whose staff may remotely access the portal from outside the UK. Where this occurs, it is treated as an international transfer under UK GDPR, and is covered by appropriate legal safeguards, including a transfer risk assessment.
7. Security
We maintain appropriate technical and organisational measures to protect your information against unauthorised access, loss, or disclosure, including access controls, secure storage of clinical records, and confidentiality agreements with all staff and affiliates.
8. Your rights
You have the right to:
- Access the personal data we hold about you
- Have inaccurate data corrected
- Request deletion of your data, where applicable
- Restrict or object to certain processing
- Request a copy of your data in a portable format, where applicable
- Withdraw consent at any time, where processing is based on consent
- Complain to us, and if unhappy with our response, to the Information Commissioner’s Office (ICO)
To exercise any of these rights, contact us at enquiry@thelisteningcentre.co.uk or write to The Data Protection Officer, The Listening Centre, Energy House, 35 Lombard Street, Lichfield, Staffordshire WS13 6DP.
9. How to complain
If you believe we have not handled your personal data in accordance with data protection law, you have the right to complain to us directly, and we are required to deal with your complaint under the following process.
How to raise a complaint:
- By email: enquiry@thelisteningcentre.co.uk
- By post: The Data Protection Officer, The Listening Centre, Energy House, 35 Lombard Street, Lichfield, Staffordshire WS13 6DP
- Verbally, to any member of our team, who will ensure it is logged and passed on correctly
What happens next:
- We will acknowledge your complaint promptly (normally within 30 days of receipt, where we have not already resolved it within that time)
- We will investigate without undue delay
- We will tell you the outcome, and what action (if any) we’ve taken
If you’re not satisfied with our response, or if you’d prefer to raise the matter directly, you can complain to the ICO:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF ico.org.uk | 0303 123 1113
10. Cookies
Please see our separate Cookie Policy for details of the cookies used on this website and how to manage your preferences.
11. Changes to this policy
This policy is effective from 1st July 2026. We review it regularly and will update it when our practices or the law changes. Material changes will be dated and noted here.
Version history:
- 1 Jul 2026: Updated to reflect Data (Use and Access) Act 2025 requirements, including formal complaints procedure
- 18 Nov 2024: Previous version
12. Contact us
Questions about this policy, or about how we handle your data, can be sent to enquiry@thelisteningcentre.co.uk.