Privacy Policy 

Fairwell Spring Counselling and Psychotherapy Counselling and Supervision
Best Practice Policy & Checklist

Adoption and review

Practitioner adopting this policy

Natalie O’Sullivan

Practice name

Fairwell Spring Counselling and Psychotherapy

Adoption date

08/10/2026

Review date / next review date

08/10/2027

This policy is adopted by the individual practitioner named above for their own independent practice. The practitioner remains responsible for ensuring that their practice complies with applicable law, professional standards, insurance requirements and any requirements of their professional body. It may be adapted by another sole trader for their own practice, but each practitioner is individually responsible for the policy they adopt and for how it is implemented.

This policy is intended to be available to clients as a clear statement of the standards and arrangements that support safe, ethical and accountable practice. It should be reviewed at least annually and sooner where there is a significant change in professional requirements, law, the service offered or the practitioner’s circumstances.

1. Purpose and scope

This policy sets out the practitioner’s approach to safe, ethical, respectful and accountable counselling and psychotherapy practice. It applies to the practitioner’s own independent work, including in-person, telephone and online work where these are offered.

Where the practitioner also works for an employer, placement or other organisation, that organisation’s policies and procedures apply to that work. This policy relates to the practitioner’s independent sole-trader practice.

2. Client information, contracting and professional boundaries

• Provide clients with clear and accessible information about the service, including the practitioner’s identity, qualifications, experience and scope of practice.
• Use a written client agreement or contract covering, as relevant, session arrangements, fees, cancellations, contact between sessions, confidentiality and its limits, supervision, complaints, breaks and endings.
• Explain how personal information and records are handled and make the privacy notice available.
• Maintain appropriate professional and personal boundaries, including boundaries relating to social media, gifts, dual relationships, reports, letters and recordings.
• Review and update the working agreement when the service or circumstances materially change.

3. Confidentiality, privacy and records

• Maintain a clear privacy notice explaining what personal information is collected, why it is used, how it is stored and protected, relevant sharing, retention and disposal, and the individual’s data-protection rights.
• Keep records that are factual, relevant and proportionate, and store them securely with access appropriately restricted.
• Explain foreseeable limits to confidentiality before work begins, including safeguarding, legal requirements and the use of supervision.
• Share information only with informed agreement or where there is a lawful and ethically justified basis for doing so, recording significant decisions and the reasons for them.
• Maintain appropriate arrangements for data security, retention, secure disposal and response to a data or confidentiality incident.
• Assess whether ICO registration/data-protection fee requirements apply to the independent practice and keep this under review.

4. Safeguarding and response to risk

The practitioner will maintain safeguarding knowledge, training, policies and procedures appropriate to the client groups with whom they work. Relevant safeguarding information and procedures will be available to clients.

• Know how to access the appropriate local safeguarding routes for adults at risk and for children and young people where relevant to the practice.
• Respond promptly to immediate danger or serious risk and contact emergency services where necessary.
• Listen carefully, avoid leading questions, do not promise secrecy, and explain what may need to happen next.
• Record safeguarding concerns, decisions, consultations, information shared and follow-up factually and promptly.
• Seek appropriate consultation or supervision while recognising that urgent action must not be delayed while waiting for supervision.
• Keep safeguarding training appropriate to the practitioner’s role and client groups under review.

5. Supervision

The practitioner will engage in regular and adequate supervision appropriate to their practice, experience, training, caseload and the complexity of their work, in accordance with current BACP membership and Ethical Framework requirements where these apply. The practitioner is responsible for ensuring that their supervision arrangements are appropriate and for bringing all relevant aspects of their practice to supervision.

The practitioner will keep an appropriate record of supervision and periodically review the adequacy of their arrangements. They will consider their knowledge, skills and competence in relation to the current SCoPEd framework and any relevant BACP competence frameworks, using supervision to support reflection, ethical practice, development and client safety.

Supervision does not transfer responsibility for an independent practitioner’s practice to their supervisor. The practitioner remains professionally accountable for their own work and decisions.

6. Competence, SCoPEd, CPD and insurance

• Work within the practitioner’s training, knowledge, skills and experience and accurately describe the services offered.
• Use the current SCoPEd framework, where relevant, as a reference point for reflecting on competence and professional development.
• Discuss areas of uncertainty, new client groups, modalities, complex work and development needs in supervision.
• Maintain relevant continuing professional development and records of learning and reflection.
• Maintain appropriate professional indemnity and liability insurance for the services, client groups, settings and delivery methods used.
• Refer, signpost, seek consultation or undertake further development where work falls outside current competence.

7. Complaints, concerns and professional accountability

• Provide clients with clear information about how to raise a concern or complaint and any relevant external route.
• Respond to concerns fairly, promptly and respectfully, keeping an appropriate record of the concern, response and outcome.
• Where something has gone wrong, take reasonable steps to limit harm, be appropriately open with those affected and meet any legal or professional reporting duties.
• Use supervision and appropriate professional consultation to support ethical decision-making while retaining personal responsibility for decisions.

8. Online, telephone, digital and AI-supported practice

• Use appropriate privacy, identity, location, emergency-contact and connection-failure arrangements for remote work.
• Use secure devices, platforms and communication methods appropriate to confidential therapeutic work.
• Consider competence, privacy, confidentiality, transparency and consent before using digital or AI tools in connection with professional work.
• Do not enter identifiable client information into an AI system without an appropriate lawful basis, transparency, safeguards and informed consent where required.
• Retain professional judgement and responsibility for all clinical, ethical and safeguarding decisions.

9. Accessibility, equality and practitioner wellbeing

• Take reasonable steps to make the service accessible and communicate in ways appropriate to individual client needs.
• Consider reasonable adjustments and barriers to access.
• Practise respectfully and without unjustified discrimination.
• Monitor personal health, wellbeing, workload and circumstances that may affect safe and effective practice, using supervision and other support and making adjustments where necessary.

10. Breaks, endings and continuity of care

• Give reasonable notice of planned breaks and endings wherever possible.
• Plan for unexpected interruption to practice and take reasonable steps to reduce disruption or risk to clients.
• Maintain a current written clinical will or continuity arrangement, including a suitable person who has agreed to act if the practitioner becomes unable to contact clients.
• Keep essential client contact information securely and separately, with clear instructions about how the agreed clinical-will contact can access only the information needed if the arrangement is activated.
• Review the clinical will/continuity arrangements periodically and whenever relevant details change.

11. Review of this policy

The practitioner will review this policy at least annually and sooner where there is a material change in law, professional standards, BACP requirements, SCoPEd or relevant competence frameworks, insurance requirements, the services offered, client groups or identified risks. The practitioner adopting the policy is responsible for keeping their own version current.

Best Practice Checklist

This checklist is an add-on to the Best Practice Policy. It is intended as a practical periodic review for the individual sole trader. It does not transfer responsibility to a supervisor or any other person.

Practitioner

Natalie O’Sullivan

Practice

Fairwell Spring Counselling and Psychotherapy

Date reviewed

07/10/2026

Next review date

01/10/2027

Client agreements and boundaries

* My client agreement/contract is current and reflects the service I actually provide.

*My fees, cancellations, contact arrangements, confidentiality, complaints, breaks and endings are clear.

* My professional boundaries, including social media and between-session contact, remain appropriate.

Privacy, confidentiality and records

* My privacy notice is current and available to clients.

* My records are proportionate, factual and securely stored.

* My retention, disposal and data-security arrangements are current.

* I have reviewed whether ICO registration/data-protection fee requirements apply to my practice.

Safeguarding and risk

* My safeguarding policy/procedure is current and available to clients.

*I know how to access current local adult and child safeguarding routes relevant to my work.

* My safeguarding training is adequate and current for my client groups and role.

* I know what I would do and record if an urgent safeguarding or risk concern arose.

Supervision, competence and SCoPEd

* I am engaging in adequate regular supervision appropriate to my practice and current BACP requirements where applicable.

* I keep an appropriate record of supervision and review whether it remains adequate.

* I bring significant difficulties, ethical issues, safeguarding matters and areas of uncertainty to supervision.

* I have considered my current competence and development needs in relation to SCoPEd and relevant BACP competence frameworks.

* I remain responsible for my own independent practice and professional decisions.

CPD and insurance

* My professional indemnity/liability insurance is current and covers the work and delivery methods I provide.

* My CPD record is current and reflects the needs of my practice.

* I am working within my competence and know when I would seek consultation, further training, referral or signposting.

Online, telephone, digital and AI

* My remote-working arrangements cover privacy, client location, emergency contact and connection failure.

* My devices, platforms and communications are appropriately secure.

* Any digital or AI use has been considered for confidentiality, data protection, transparency, consent and professional accountability.

Complaints, accessibility and wellbeing

* Clients can access clear information about complaints and concerns.

* I have considered accessibility and reasonable adjustments within my service.

* I have considered whether my workload, health or wellbeing is affecting safe and effective practice.

Clinical will and continuity

* I have a current clinical will/continuity arrangement.

* The person I have named has agreed to the role.

* They know where the necessary client contact information is securely held and how it can be accessed if the arrangement is activated.

* My client contact information is kept securely and separately from unnecessary clinical material.

* I have reviewed the arrangement following any relevant change.