Data Retention and Secure Disposal Policy

Helen Ward Therapy
Trading name of ResolvedRM Ltd

Version: 1.0
Effective Date: 30/05/26
Review Date: 30/05/27

1. Purpose

Helen Ward Therapy is committed to ensuring that personal information is retained only for as long as necessary and is securely disposed of when it is no longer required.

This policy sets out the principles and procedures followed for the retention, storage, review and secure disposal of personal data in accordance with:

the UK General Data Protection Regulation (UK GDPR);
the Data Protection Act 2018;
professional ethical obligations, including the BACP Ethical Framework for the Counselling Professions.

2. Scope

This policy applies to all personal and confidential information held by Helen Ward Therapy, including:

client records;
assessment information;
clinical notes;
correspondence;
appointment records;
financial records;
enquiry records;
electronic files;
paper documents;
emails and electronic communications containing personal information.

3. Data Retention Principles

Helen Ward Therapy follows the UK GDPR principle of storage limitation, meaning that personal information will not be retained for longer than is necessary for the purpose for which it was collected.

Information will only be retained where there is a legitimate, professional, legal or regulatory reason to do so.

Retention periods are determined by considering:

legal and regulatory requirements;
professional guidance;
the nature of the information;
the purpose for which the information was collected;
potential risks to the client or practice;
the need to demonstrate appropriate professional care.

4. Clinical Record Retention

Clinical records are retained to support:

continuity and safety of care;
professional accountability;
responding to future enquiries;
meeting professional and legal obligations.

Helen Ward Therapy retains client records for:

Seven years following the end of therapy in accordance with professional guidance and insurance requirements.

Where a longer retention period is required due to legal proceedings, safeguarding considerations, regulatory requirements or other legitimate reasons, records may be retained for longer.

5. Financial Records

Financial records are retained in accordance with applicable HMRC requirements.

These may include:

invoices;
payment records;
accounting information;
tax-related documentation.

6. Review of Retained Information

Information retained by Helen Ward Therapy will be reviewed periodically to ensure that:

it remains necessary to retain the information;
information that is no longer required is securely deleted or destroyed;
records remain accurate and appropriately stored.

7. Secure Disposal Principles

When personal information reaches the end of its retention period, it will be securely disposed of in a manner that prevents:

unauthorised access;
reconstruction;
accidental disclosure;
misuse of confidential information.

Disposal methods will be appropriate to the type of information being destroyed.

8. Disposal of Paper Records

Paper records containing confidential or personal information will be securely destroyed by one of the following methods:

using a confidential waste disposal service provided by an approved professional organisation;
secure cross-cut shredding;
another method that renders the information permanently unreadable and unrecoverable.

Where a confidential waste disposal service is used, Helen Ward Therapy will ensure that the provider offers appropriate security assurances and, where applicable, maintains relevant data protection standards.

Confidential waste will not be placed in general household recycling or waste where this could result in unauthorised access to personal information.

9. Disposal of Electronic Records

Electronic records will be securely deleted using appropriate methods to reduce the risk of recovery.

This may include:

secure deletion from devices and systems;
removal from cloud storage;
secure wiping of devices before disposal or reuse;
ensuring any backups are managed appropriately.

Where electronic devices containing personal information are disposed of, they will be securely wiped or physically destroyed where necessary.

10. Disposal by Alternative Methods

Where Helen Ward Therapy undertakes disposal independently, the method used must ensure that confidential information is permanently destroyed and cannot reasonably be reconstructed.

Any disposal method must be undertaken safely, responsibly and in accordance with applicable legal and environmental requirements.

11. Records of Disposal

Where appropriate, records of disposal may be maintained, including:

date of disposal;
type of records destroyed;
method of destruction;
disposal provider used (where applicable).

12. Responsibilities

As a sole practitioner, Helen Ward is responsible for ensuring:

information is retained appropriately;
retention periods are reviewed;
confidential information is securely stored;
disposal methods are secure and appropriate;
disposal providers are appropriately selected.

13. Data Breaches

If personal information is lost, accessed without authorisation, or disposed of incorrectly, this will be managed in accordance with the Data Breach Procedure.

Where required, appropriate action will be taken, including notification to affected individuals and the Information Commissioner's Office (ICO).

14. Policy Review

This policy will be reviewed annually or sooner where there are changes to:

legislation;
professional guidance;
technology;
business processes.