Privacy notice
This notice explains how your personal information may be collected, used, stored and shared in connection with pastoral counselling and wellbeing services.
A. Who is responsible for your information?
Responsible party: Elri Kuhn / Elri Kuhn Counselling.
B. What information may be collected?
Depending on the service you use, the practice may collect:
- Contact and identification details, such as your name, date of birth, email address and telephone number.
- Emergency contact details.
- Booking, attendance, payment and cancellation records.
- Information you choose to share about your personal circumstances, relationships, emotional wellbeing, beliefs or spiritual life.
- Session notes and relevant correspondence.
- Technical information generated by the booking, communication or payment platforms.
Some information may be sensitive personal information. The practice will take particular care with such information and handle it in accordance with applicable law.
C. Why is information collected?
Your information may be processed for the following purposes:
- To respond to enquiries and arrange appointments.
- To provide pastoral counselling and wellbeing support.
- To maintain appropriate session notes and professional records.
- To manage payments, refunds, cancellations and credits.
- To contact you about appointments or changes to the service.
- To protect client safety and meet applicable legal, ethical and professional obligations.
- To obtain appropriate supervision or consultation.
- To respond to lawful requests or resolve disputes.
Personal information will not be used for unrelated purposes without an appropriate lawful basis.
D. Lawful processing
The practice will process personal information in accordance with the Protection of Personal Information Act (POPIA) and other applicable law.
Depending on the circumstances, processing may be necessary to provide the service you have requested, meet a legal obligation, protect a legitimate interest or rely on another lawful basis recognised by POPIA. Where consent is the appropriate basis, it will be requested clearly and may be withdrawn, subject to legal and contractual limits.
E. Who may receive information?
Your information may be accessed by the counsellor and, where necessary and appropriate:
- A professional supervisor or consultant, subject to confidentiality safeguards.
- Booking, electronic-signature, communication, storage or payment service providers who process information on behalf of the practice.
- Another professional or service to whom you have agreed to be referred, where sharing is appropriate and lawful.
- A person or authority where disclosure is legally required or justified by a serious safety concern.
The practice will aim to limit disclosure to what is reasonably necessary. Third-party service providers may process information in other countries. The practice must check the relevant providers’ privacy and security arrangements and comply with POPIA’s rules for any cross-border transfer.
F. How information is stored and protected
The practice will take reasonable technical and organisational steps to protect personal information against loss, unauthorised access, misuse, alteration or disclosure.
Records may be stored electronically through secure systems used for scheduling, communication, electronic signatures, payment processing and recordkeeping. No digital system can be guaranteed completely secure.
Access to records will be limited to people who need the information for an authorised purpose.
G. How long is information retained?
Information will be retained only for as long as reasonably necessary for the purpose for which it was collected, subject to applicable legal, professional, insurance, accounting and recordkeeping requirements.
When information is no longer required, it will be securely deleted, destroyed or de-identified where appropriate and lawful.
H. Your rights
Subject to applicable law, you may have the right to:
- Ask whether the practice holds personal information about you.
- Request access to information held about you.
- Request correction or updating of inaccurate or incomplete information.
- Request deletion or destruction where legally appropriate.
- Object to certain forms of processing or withdraw consent where consent is the basis for processing.
- Raise a complaint with the Information Regulator or another relevant authority.
These rights may be subject to lawful limits, including duties to retain certain records or protect the rights of others.
I. Communication and marketing
The practice may contact you about appointments, booking changes, payments or matters directly related to your counselling.
Your information will not be added to a marketing list or used for unrelated promotional messages without an appropriate lawful basis and, where required, your consent. Any optional marketing consent should be collected separately and should not be a condition of receiving counselling.
