Elizabeth Downing Counselling

Privacy Policy & Cookie Policy

Effective date: 23 July 2026

Privacy Notice

This Privacy Policy explains how I, Elizabeth Downing (“I”, “me” or “my”), collect, use, store and protect your personal information when you contact me or visit my website. 

I am committed to protecting your privacy and handling your personal information responsibly, transparently and in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and other applicable data protection legislation.

ICO registration number: ZA102947

Contact email: info@elizabethdowningcounsellor.com

Please read this Privacy Policy carefully. If you have any questions, you are welcome to contact me using the details at the end of this document.

Additional information about my counselling practice, including confidentiality, how sessions work, and other aspects of working together, will be provided before we commence counselling. This ensures you have a clear understanding of my practice arrangements and gives you the opportunity to discuss any questions before therapy begins.

Who I Am

Elizabeth Downing is the data controller responsible for the personal information collected through this website and in connection with my counselling practice.

As the data controller, I decide how and why your personal information is processed.

My Lawful Basis for Processing

Under UK GDPR, I process personal information using one or more of the following lawful bases:

  • performance of a contract
  • legitimate interests
  • compliance with a legal obligation
  • your consent (where required).

Where I process health information, I also rely upon the additional conditions that permit the provision of health and counselling services and the establishment, exercise or defence of legal claims where applicable.

The Information I Collect

Depending on how you interact with my practice, I may collect:

Enquiry information

If you contact me by telephone, email or via my website, I may collect:

  • your name
  • telephone number
  • email address
  • preferred method of contact
  • the content of your enquiry
  • any other information you choose to provide.

Website enquiries are sent directly to my email inbox and are used only to respond to your enquiry and, where appropriate, discuss arranging counselling.

This form is provided by Contact Form 7, a plugin installed on this WordPress site. Submissions are sent to my email inbox and are not stored in a public database on the site by default.

Spam filtering (Google reCAPTCHA v3)

This site uses Google reCAPTCHA v3 to help distinguish human visitors from automated bots when the contact form is submitted. Unlike older versions, reCAPTCHA v3 runs invisibly in the background and does not require you to click a checkbox or solve a challenge — it scores your interaction with the site based on behavioural signals and assigns a probability that you are a bot. As part of this, reCAPTCHA collects information such as your IP address, browser and device information, and may set cookies and use other tracking technologies. This data is sent to and processed by Google. Because it runs on every page load (not just on submission), reCAPTCHA v3 may collect data even if you don’t ultimately submit the form. Use of reCAPTCHA is subject to Google’s Privacy Policy and Terms of Service .Google acts as a data processor for reCAPTCHA data collected on this site; I remain the data controller for this information, in line with Google’s April 2026 update to its reCAPTCHA terms

Automatically collected information

Like most websites, this site may log standard technical data (IP address, browser type, pages visited) via server logs or analytics tools. This site uses Google Analytics 4 for this purpose.

Cookies

This site uses the following cookies:

Strictly necessary (no consent required)
These are set by WordPress itself and by Complianz, the cookie consent plugin used on this site, to remember your consent choices and keep the site functioning (e.g. login sessions, security). These don’t require consent under UK PECR guidance because the site cannot function without them.

Analytics — Google Analytics 4 (consent required)
This site uses Google Analytics 4 to understand how visitors use the site (e.g. which pages are viewed, how long visitors stay). GA4 sets cookies (including _ga and _ga_*) that identify your browser to Google for this purpose. These cookies are not strictly necessary and only load if you accept analytics cookies via the consent banner. Use of Google Analytics is subject to Google’s Privacy Policy.

Spam prevention — Google reCAPTCHA v3 (legitimate interest, not gated by consent)
This site uses Google reCAPTCHA v3 on the contact form to distinguish genuine enquiries from automated spam and bot submissions. reCAPTCHA runs invisibly on every page load — it does not require you to click a checkbox — and assesses behavioural signals to score the likelihood that a visitor is a bot. As part of this, reCAPTCHA may set cookies associated with Google (including cookies normally linked to a Google account, if you are signed into one in your browser) and collects data such as your IP address and browser/device information, which is sent to and processed by Google.

reCAPTCHA runs regardless of your cookie consent choice. This is a deliberate decision: unlike analytics or advertising cookies, spam-detection tools have to operate before any interaction takes place in order to be effective, so they are treated here as necessary to protect the site and my inbox from abuse (a legitimate interest under Art. 6(1)(f) UK GDPR), rather than something you opt into. Use of reCAPTCHA is subject to Google’s Privacy Policy and Terms of Service. 

 

How I Use Your Information

Purpose

Data used

Legal basis (UK GDPR)

Responding to your enquiry

Name, email, phone, message

Art. 6(1)(b) — necessary to take steps at your request prior to entering into a contract for counselling services

Spam prevention

IP address, browser/device info, behavioural signals via reCAPTCHA

Legitimate interests (Art. 6(1)(f)) — protecting the site and my inbox from abuse

Understanding site usage

Pages visited, browser/device info via Google Analytics 4

Consent (Art. 6(1)(a)) — only where you accept analytics cookies

Where an enquiry concerns sensitive/health-related information

Message content

Explicit consent (Art. 9(2)(a)) — because counselling enquiries often reveal information about mental health

You are not obliged to provide any information via the contact form, but I won’t be able to respond to your enquiry without at least a name and a way to contact you.

Communication

If you contact me by email, telephone or text message, I will retain sufficient information to respond to your enquiry and manage appointments.

Please be aware that email and text messaging cannot always be guaranteed to be completely secure. For this reason, I recommend avoiding sending highly sensitive personal information by these methods unless necessary.

How Your Information Is Stored

I take appropriate technical and organisational measures to protect your personal information.

These measures may include:

  • password-protected computers and devices
  • encrypted storage where appropriate
  • secure email services
  • secure cloud storage provided by reputable suppliers
  • regular software updates
  • restricted access to client information
  • secure disposal of paper and electronic records when no longer required.

Only those who have a legitimate need to access your information will do so

Who I share your information with

  • Google (reCAPTCHA, Google Analytics) — bot/spam prevention and site usage analytics, as described above.
  • Titan — hosts the inbox that receives contact form submissions.
  • IONOS — hosts the website and any server logs.

I do not sell your information, and I do not share counselling-related enquiry content with any third party for marketing purposes.

Where a processor is based outside the UK/EEA (for example, Google is a US company), transfers are made under the UK-US Data Bridge (the UK extension to the EU-US Data Privacy Framework), an adequacy mechanism recognised under UK GDPR, provided Google’s relevant entity is certified under it. Where this doesn’t apply, transfers rely on Standard Contractual Clauses as a fallback.

How Long I Keep Information

I only keep personal information for as long as necessary.

  • Contact form enquiries that don’t lead to counselling work: deleted after 12 months.
  • Enquiries that lead to a counselling relationship: retained in line with my case-note retention policy
  • Data sent to Google for spam-checking (reCAPTCHA) and site analytics (Google Analytics): retained by Google per their own policy; I don’t separately store this.

Your Rights

Under UK GDPR you have the right to:

Under UK GDPR you have the right to:

  • Access the personal information I hold about you
  • Ask me to correct inaccurate information
  • Ask me to delete your information (subject to my professional record-keeping obligations)
  • Object to or restrict certain processing
  • Withdraw consent at any time (this won’t affect processing already carried out)
  • Complain to the ICO (ico.org.uk) if you believe I have mishandled your data

To exercise any of these rights, contact me at info@elizabethdowningcounsellor.com

Some of these rights are subject to legal or professional exemptions.

Data Security Incidents

If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, I will follow the requirements of UK GDPR, including notifying the Information Commissioner’s Office and affected individuals where legally required.

Changes to This Privacy Policy

This Privacy Policy may be updated from time to time to reflect changes in legislation, professional guidance or the way my practice operates.

The most recent version will always be available on my website.

Contact

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact:

Elizabeth Downing

Email: info@elizabethdowningcounsellor.com

Complaints

If you have concerns about how I have handled your personal information, please contact me in the first instance so that I have the opportunity to resolve your concerns. A copy of my complaints procedure is available from complaints@elizabethdowningcounsellor.com

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

Information about making a complaint can be found on the ICO website: https://ico.org.uk/

Last reviewed: July 2026