Record-Keeping & Data Retention Policy — Carl Argent Counselling and Coaching

1. Purpose

This policy explains what records I keep, where they are held, how long I keep them and how they are destroyed. It follows the UK GDPR, the Data Protection Act 2018 and the BACP Ethical Framework (2026), which asks that records are factual, adequate and relevant to the service, stored securely, and include all communications and information held about clients. My Privacy Notice gives the full list of services I use.

2. What my records include

• Clinical records: brief, factual session notes, your working agreement, questionnaires and assessments, and any significant correspondence. Notes summarise themes and agreed actions; I do not record conversations word for word.
• Communications: the emails and messages we exchange, including between-session summaries or homework I send. These form part of your record wherever they are held.
• Administrative records: contact details, an emergency contact, optional GP details, attendance and payment records.
• My professional decisions: where I make a significant ethical or safeguarding decision about our work, I record my reasoning and any supervision discussion, as the Framework requires.

3. Where records are held

• My booking system: client records, agreements, session notes, questionnaires and payment status are held in my own booking system on my website (WordPress, hosted by IONOS). Client details are stored in encrypted form.
• Email: Apple iCloud Mail and Google Workspace, protected by strong passwords and secure sign-in.
• Google Drive: some practice documents and session-note records.
• My devices: password protected and encrypted.
• Paper: any paper notes are kept in a locked cabinet to which only I have the key.
• Messages: WhatsApp and text messages are not backed up. Anything relevant is copied to your record and the chat is then deleted from my phone (see my Digital Communications Policy).

4. Retention periods

My booking system checks every month for records that have reached the end of their retention period. I confirm each deletion before it happens.

5. Secure disposal

• Paper: cross-cut shredded.
• Electronic: permanently deleted from my booking system, email and storage, including deleted-items folders.

6. Clinical will and clinical executor

I have a clinical will and a named clinical executor who is bound by confidentiality. If I become seriously ill, unable to work or die, my executor will:

• contact current and recent clients to let them know, and help them find other support;
• inform my supervisor, BACP and my insurer;
• keep and then destroy records in line with this policy.

My executor uses only the information needed for these tasks.

7. Your rights

• Access: you can ask for a copy of your records. I will respond within one calendar month, usually free of charge.
• Correction: you can ask me to correct factual errors.
• Erasure: you can ask me to delete your information. This right is not absolute: I may keep clinical records until the end of the retention period so I can account for my work and respond to any complaint or claim.

8. Suspension of deletion

If a complaint, legal action or insurance claim is raised or threatened during the retention period, no relevant records will be deleted until the matter is resolved.