Policies & Privacy Notice
Policies, Client Agreement and Privacy Notice
This document is intended to give you a clear understanding of what we are both agreeing to when we begin working together. I have tried to keep it as straightforward and jargon-free as possible, while making sure that you understand how I work, how your information is handled and what your rights are.
Please take the time to read it carefully. If there is anything you are unsure about, or if you have any questions, please ask me at any point before or during our work together.
Therapy is a collaborative process, and I want you to feel able to discuss any concerns you may have about our work.
About Me and My Professional Responsibilities
My name is Hayley Tarabas, and I practise as Black Pearl Therapy.
I am a Professional Accredited member of the National Counselling and Psychotherapy Society (NCPS), membership number NCPS22-02013. I practise in accordance with the NCPS Code of Ethical Practice and am accountable to the NCPS.
Information about the NCPS and its Code of Ethics can be found at:
https://ncps.com/about-us/code-of-ethics
I am also a registered member (awaiting accreditation status) of the British Association for Counselling and Psychotherapy (BACP) membership number 00969281 and practise in accordance with the professional and ethical requirements applicable to my membership category.
I maintain appropriate professional indemnity insurance through Holistic Services Insurance.
I am registered with the Information Commissioner's Office (ICO).
ICO registration reference: ZB493703
Sessions and Fees
An individual counselling or psychotherapy session lasts 50 minutes.
My current fees are:
- £60 per session
- £70 per session for appointments from 4.30pm onwards
- £90 per 60 minute couples therapy session
Payment is required at least 24 hours before your appointment.
If my fees increase, I will give you as much notice as reasonably possible.
Cancellation and Missed Appointments
If you have booked a session but are unable to attend, please let me know as soon as possible.
If you cancel with less than 24 hours' notice, the full session fee will normally be retained.
If you provide more than 24 hours' notice, the fee may be refunded or transferred to your next session.
I also ask that you give as much notice as possible if you know that you will need to miss a session because of a holiday or another planned absence.
I will give you the same consideration and will provide as much notice as possible if I need to cancel or rearrange one of our sessions.
Confidentiality
A central part of therapy is creating a space where you can feel safe enough to speak openly.
Everything you tell me during our work together will be treated as confidential, subject to the limits explained below.
I will not normally share information about you or our work with anyone else without your knowledge or agreement unless there is a legal, ethical or safeguarding reason that makes disclosure necessary.
Supervision
As part of my professional and ethical responsibilities, I attend regular clinical supervision.
Supervision helps therapists to reflect on their work and ensure that they are practising safely, ethically and effectively.
I may discuss aspects of our work during supervision. Wherever possible, information will be anonymised and identifying details will not be shared unnecessarily.
My supervisor is also bound by professional duties of confidentiality.
Use of Material for Training, Assessment or Professional Development
From time to time, anonymised material may be used for purposes such as:
- professional supervision;
- peer supervision;
- professional training;
- academic assessment; or
- professional development.
Any material used for these purposes will be thoroughly anonymised so that you cannot reasonably be identified.
Your identifiable clinical information will not be used for these additional purposes without an appropriate reason or agreement.
If you would prefer that anonymised material from our work is not used for purposes beyond my own professional supervision, please let me know.
Limits to Confidentiality
Although confidentiality is extremely important, there are circumstances in which I may be legally or ethically required to disclose information.
Where possible and appropriate, I will normally discuss this with you before making a disclosure.
However, there may be circumstances in which it would not be appropriate, safe or legally possible to do so.
Circumstances in Which I May Be Legally Required to Disclose Information
I may be required to disclose information where there is a legal obligation to do so. This may include circumstances involving:
- information that may assist in preventing acts of terrorism or assist in bringing someone involved in terrorism to justice, where a legal duty to disclose applies;
- certain information relating to terrorist financing or related criminal activity;
- the mandatory reporting of known cases of female genital mutilation involving girls under the age of 18 where the relevant legal reporting duty applies;
- compliance with a valid court order or other legally enforceable requirement;
- circumstances in which legislation creates a specific duty to provide information; or
- other situations in which disclosure is required by law.
Where information is requested by a third party, including the police or another authority, I will consider the legal basis for the request and will only disclose information where I am legally required or otherwise legally permitted to do so.
I may seek professional, legal or supervisory advice where appropriate.
Circumstances in Which I May Need to Consider Breaking Confidentiality
I may need to consider sharing information if I believe that there is a serious and immediate risk of significant harm to you or another person.
This could include circumstances where there is a serious safeguarding concern or where disclosure is necessary to help prevent serious harm.
Any decision to disclose confidential information will be considered carefully. Wherever possible, I will only share the minimum amount of information necessary and only with an appropriate person or organisation.
Seeing Each Other Outside Therapy
To protect your confidentiality and maintain appropriate professional boundaries, if we see each other outside of the therapy setting, I will not normally acknowledge you unless you choose to acknowledge me first.
This is not intended to be unfriendly. It is simply intended to avoid revealing our therapeutic relationship to anyone else or putting you in an awkward position.
Practice Continuity and Clinical Will
As a sole practitioner, I have a responsibility to make arrangements for the continuity of my practice should I unexpectedly become unable to work.
This may include circumstances such as serious illness, incapacity or death.
I have arrangements in place so that an appropriately qualified and trusted professional can take limited and necessary action in relation to my practice.
In the event that I am suddenly unable to continue practising, the person responsible for these arrangements may be given access to the minimum information necessary to:
- contact current clients and inform them that I am unable to continue practising;
- provide information about appropriate sources of support;
- assist with referrals or onward support where possible and appropriate;
- ensure that clients are not left without communication during an unexpected interruption to therapy;
- manage the secure storage and retention of clinical records; and
- deal with necessary professional and administrative matters relating to my practice.
Any person acting in this capacity will be required to respect appropriate standards of confidentiality and data protection.
My designated professional/clinical executor is: Anne Millne-Riley at Awareness Therapy www.awarenesstherapy.co.uk
CCTV
CCTV operates around the exterior and entrance areas of the premises where I work, including the front door.
This may capture your image as you approach or leave the premises.
CCTV is used for security and the prevention or investigation of crime.
There is no audio or video recording equipment inside the therapy room, and therapy sessions are not recorded unless this has been specifically discussed and agreed with you in advance.
CCTV recordings are normally retained for no longer than three months, unless they are required in connection with an incident, legal matter or law enforcement investigation.
Online Therapy and Emergencies
If we are working together online, I may ask you to provide information about your location and an emergency contact where appropriate.
This is to enable appropriate action to be taken if I become seriously concerned about your immediate safety during an online session.
Online therapy is not an emergency service.
If you are in immediate danger or require urgent assistance, you should contact the emergency services by calling 999 or attend your nearest Accident and Emergency department.
Professional Concerns and Complaints
I hope that if you have any concerns about our work together, you will feel able to discuss them with me.
I will always aim to listen to concerns seriously and respectfully and, where possible, work with you to resolve them.
You are not required to raise a concern with me before contacting a professional body if you do not feel comfortable doing so.
If you believe that I have acted unethically or breached the professional standards that apply to my practice, you may also raise your concerns with the relevant professional body.
As a Professional Accredited member of the NCPS, I am accountable to the NCPS Code of Ethical Practice.
Information about the NCPS complaints process can be obtained from the NCPS.
If your concern relates to my BACP membership or professional conduct under BACP requirements, you may also contact BACP in accordance with its applicable complaints procedure.
A complaint about my professional practice is different from a complaint about how I have handled your personal information. Information about making a data protection complaint is provided later in this Privacy Notice.
Privacy Notice
Who Is Responsible for Your Personal Information?
I, Hayley Tarabas, trading as Black Pearl Therapy, am responsible for the personal information that I collect and process in connection with my practice.
For the purposes of UK data protection law, I am the Data Controller for your personal information.
Where I use other organisations to provide services on my behalf, such as secure software, cloud storage or accounting services, they may process information on my behalf in accordance with appropriate arrangements.
The Information I Collect
The information I may hold about you includes:
- your name;
- your contact details, such as your email address and telephone number;
- information relevant to arranging and managing appointments;
- information that you provide during therapy;
- clinical notes relating to our work together;
- information about interventions or approaches used during therapy;
- emails, texts or other messages exchanged between us;
- information provided by a third party, where appropriate and lawful;
- information relating to payment and accounting; and
- information that may be necessary to respond to a complaint, legal claim or professional investigation.
Some of the information you provide may be particularly sensitive and may fall within the definition of special category personal data under UK data protection law.
This may include information about:
- physical or mental health;
- sexuality;
- racial or ethnic origin;
- religious or philosophical beliefs; or
- other highly personal aspects of your life.
Why I Use Your Information
I primarily use your personal information to:
- provide counselling or psychotherapy;
- arrange and manage appointments;
- maintain appropriate clinical records;
- communicate with you about our work;
- ensure the safe and effective administration of my practice;
- meet professional, ethical and insurance requirements;
- respond to concerns or complaints;
- protect the safety and wellbeing of clients and others where necessary;
- comply with legal obligations; and
- manage accounting and business administration.
I will not use your clinical information for unrelated purposes.
Lawful Basis for Processing Your Information
UK data protection law requires me to have a lawful basis for processing your personal information.
The lawful basis that applies will depend on the particular information and the reason it is being processed.
In many circumstances, I process personal information because it is necessary to provide and manage the professional service that we have agreed.
I may also process information where this is necessary for my legitimate interests, provided that your rights and interests do not override those interests.
This may include activities such as:
- maintaining appropriate professional records;
- managing and protecting my practice;
- responding to complaints or legal claims;
- ensuring the security and administration of my services; and
- meeting relevant professional responsibilities.
Special Category Information
Therapy may involve the processing of special category personal information.
Where this applies, I will only process this information where there is an appropriate additional condition under UK data protection law.
This may include circumstances where processing is necessary for the provision of health or social care or treatment, subject to appropriate safeguards and duties of confidentiality.
I will only collect and use sensitive information that is reasonably necessary for the purposes of providing therapy and meeting my professional, ethical and legal responsibilities.
Criminal Offence Information
Information relating to criminal allegations, proceedings or convictions is subject to additional protections under UK data protection law.
If such information becomes relevant to our therapeutic work or to my legal, safeguarding or professional responsibilities, I will only process it where there is an appropriate lawful basis and legal condition for doing so.
Who I May Share Your Information With
Your information will normally be kept confidential.
However, information may be shared where necessary and appropriate with:
- my clinical supervisor;
- a professional responsible for my practice continuity arrangements in the event of my incapacity or death;
- your GP or another relevant professional, where appropriate and lawful;
- emergency or safeguarding services where there is a serious concern about safety;
- professional bodies where necessary in connection with a complaint or investigation;
- legal advisers, insurers or other relevant professionals where necessary to protect or establish legal rights; or
- another person or organisation where disclosure is required or permitted by law.
I will only share the information that is reasonably necessary for the relevant purpose.
If a complaint is made about me to one of my professional bodies, it may be necessary for me to provide relevant information or clinical records to assist with the investigation, where I am legally and professionally entitled or required to do so.
Where Your Information Is Stored
I take the security of your information seriously.
Depending on the type of information, your data may be stored in the following ways:
Emails
Emails exchanged between us may be stored on my computer and/or through email and cloud storage services that I use for my practice.
Mobile Phone
Information held on my mobile phone is protected by appropriate security measures, including password or code protection.
Text and Messaging Services
Texts, WhatsApp messages, Messenger messages or other electronic communications may be stored on the relevant device or platform.
For this reason, I ask that electronic messaging is used primarily for practical matters such as appointments and scheduling rather than detailed therapeutic discussions.
Clinical Notes
Clinical notes are stored separately from identifying information wherever reasonably possible.
Notes may use your first name or initials rather than your full identifying details.
Payments and Accounting
If you use online banking, PayPal or another payment service, those organisations may process information about your transaction.
Information necessary for accounting purposes may be retained and processed through my accounting systems.
Where reasonably possible, identifying information is minimised when information is transferred to accounting records.
I currently use Monzo Business Banking for accounting purposes.
Recordings
Therapy sessions are not routinely recorded.
If any recording is proposed, this will be discussed with you beforehand.
Any recording will only take place with an appropriate agreement and will be stored securely.
Data Security
I take reasonable steps to protect your personal information from:
- unauthorised access;
- accidental loss;
- destruction;
- alteration; or
- inappropriate disclosure.
Measures include password and device protection and the use of secure storage where appropriate.
No method of electronic communication or storage can be guaranteed to be completely secure.
For this reason, I encourage clients not to send highly sensitive therapeutic information through insecure communication channels where possible.
Information You Send to Me
I cannot control the security practices of every third-party service that you may choose to use to contact me.
For example, email providers, messaging platforms and social media companies may process information according to their own systems and privacy policies.
I will take reasonable steps to protect information once it is received and processed by me, but I cannot guarantee the security of information while it is being transmitted through third-party services outside my control.
How Long I Keep Your Information
I retain clinical records and relevant personal information for seven years after the end of our therapeutic work, unless a longer retention period is required or justified by law, professional guidance, insurance requirements or other relevant circumstances.
The retention period is based on my professional and insurance requirements.
When information is no longer required, it will be securely destroyed or deleted.
Paper records will be securely shredded.
Electronic records will be securely deleted where reasonably possible.
Some financial and accounting information may need to be retained for a different period in order to meet legal or accounting requirements.
Personal Data Breaches
I take the security of your information seriously.
If a personal data breach occurs, I will assess the nature of the breach and the likely risk to the rights and freedoms of the individuals affected.
Where required by law, I will report a notifiable breach to the Information Commissioner's Office (ICO) without undue delay and, where feasible, within the applicable legal timescale.
Where a breach is likely to result in a high risk to your rights and freedoms, I will inform you without undue delay unless a legal exemption applies.
I will take appropriate steps to investigate, contain and manage any breach and to minimise any potential impact.
Your Rights in Relation to Your Personal Information
You have a number of rights under UK data protection law.
These rights may apply differently depending on the circumstances and the reason your information is being processed.
The Right of Access
You may request access to the personal information that I hold about you.
The Right to Rectification
You may ask me to correct personal information that is inaccurate or incomplete.
The Right to Erasure
In certain circumstances, you may ask for your personal information to be erased.
However, this right is not absolute.
I may need to retain certain information where this is necessary to meet legal, professional, insurance or other legitimate obligations.
The Right to Restrict Processing
In certain circumstances, you may ask me to restrict the way in which your information is processed.
The Right to Data Portability
Where applicable, you may request that certain personal information is provided to you in a structured and commonly used format or transferred to another organisation.
The Right to Object
Where processing is based on legitimate interests or another relevant basis that gives rise to a right to object, you may object to that processing.
Automated Decision-Making
I do not use your personal information to make decisions about you solely through automated decision-making or profiling.
Responding to Requests About Your Information
If you make a request relating to your personal information, I will respond without undue delay and normally within the timescale required by UK data protection law.
In most cases, this will be within one month of receiving your request.
Where the law permits an extension, for example because a request is particularly complex, I will inform you accordingly.
I may need to confirm your identity before providing personal information to ensure that it is not disclosed to the wrong person.
Data Protection Complaints
If you have concerns about the way I have collected, used, stored or otherwise handled your personal information, you have the right to make a data protection complaint directly to me.
You can make a complaint by contacting me using the details below:
Email: blackpearltherapy@gmail.com
Please make it clear that your concern is a data protection complaint and provide enough information for me to understand and investigate the issue.
I will acknowledge receipt of your complaint within 30 days.
I will investigate the complaint appropriately and communicate the outcome to you without undue delay.
If you remain dissatisfied with how I have handled your personal information, you may raise your concerns with the Information Commissioner's Office (ICO).
Information about the ICO can be found at:
Social Media and Electronic Communication Policy
This section explains how Black Pearl Therapy approaches social media and electronic communication.
Technology changes frequently, and this policy may be updated from time to time.
The most recent version will be available on my website or provided on request.
Social Media Friend or Contact Requests
I do not accept friend or contact requests from current or former clients on personal social networking accounts.
This is because social media connections can potentially compromise your confidentiality or blur the boundaries of the therapeutic relationship.
For example, another person may see that we are connected and make assumptions about how we know each other.
Following Social Media Accounts
Black Pearl Therapy may have professional social media accounts.
You are free to make your own decisions about whether to follow public professional pages, but please be aware that doing so may make it possible for others to infer that you have an interest in my services.
I will not normally follow current or former clients on personal social media accounts.
Public Interaction
Please avoid using public methods of communication, such as tagging me publicly or posting detailed therapeutic information on public social media pages.
This is to help protect your privacy and confidentiality.
Messaging services such as WhatsApp or text may be used for practical matters, including appointment arrangements, but they should not normally be used for detailed therapeutic discussions.
Searching for Clients Online
I do not routinely search for information about clients online.
In exceptional circumstances, such as where I have a serious concern about your immediate safety and believe that online information may help me assess the situation, I may conduct a limited search.
If this occurs, I will normally discuss it with you at the next appropriate opportunity unless there is a compelling reason not to do so.
Reviews and Business Review Websites
You may find Black Pearl Therapy or my name listed on online business or review websites.
I may not have requested or created every listing.
Clients and members of the public are responsible for their own decisions about posting reviews.
Because of confidentiality, I will not publicly confirm or deny whether someone is or has been a client.
For the same reason, I may be unable to respond publicly to reviews that relate to therapy.
I do not request testimonials from therapy clients.
Location-Based Services
If you use location-based services or "check-in" features on your phone or social media accounts, please be aware that other people may be able to infer that you have visited my premises.
You are responsible for managing the privacy settings on your own devices and accounts.
Email Communication
Email is generally best used for practical and administrative matters.
Please avoid sending detailed therapeutic information by email where possible because email cannot be guaranteed to be completely secure.
You can email me at any time, but I may not respond immediately.
Telephone and Text Messages
Text messages may be used for practical matters such as arranging or changing appointments.
I am often unable to answer telephone calls because I may be in a session with another client.
Email is generally the preferred method for non-urgent practical communication.
Please contact me by telephone or text between 10am and 6pm, unless we have specifically agreed otherwise.
Emails may be sent at any time, although I may not respond immediately.
Ending Therapy
You are free to end therapy at any time.
Where possible, I encourage us to discuss and plan the ending together so that we can bring the therapeutic relationship to a safe and respectful close.
However, the decision to continue or end therapy remains yours.
If possible, I ask that you provide notice if you intend to end our work together.
This can give us an opportunity to:
reflect on the work we have done;
address any unfinished issues;
consider your ongoing support needs; and
bring the therapeutic relationship to an appropriate close.
I will respect your right to make the decisions that you believe are best for you.
Your Rights as a Client
You have the right to:
be treated with dignity and respect;
receive therapy within appropriate professional and ethical boundaries;
ask questions about the way I work;
raise concerns about therapy;
make decisions about whether to continue therapy;
understand the limits of confidentiality;
receive information about how your personal information is handled; and
raise concerns with an appropriate professional body or the ICO where relevant.
I aim to work in a way that is transparent, respectful and collaborative.
If you are ever unsure about anything contained in this document, please ask.
Changes to This Document
This document may occasionally need to be updated to reflect:
changes in the law;
changes to professional or ethical requirements;
changes to my practice; or
changes to the way personal information is processed.
Where a significant change affects our therapeutic agreement or the way your information is handled, I will make reasonable efforts to bring this to your attention.
Last updated: September 2026