Privacy policy

I am the Data Controller and Processor for data that I collect from client(s).

  • The basis on which I keep client data is that of “Legitimate Interests”. This means that the data is necessary for me to fulfil the contract that we have together (ie to provide therapy) and that it is data that you would reasonably expect me to hold and use.

  • For those who enquire about therapy, the data I hold includes any information you have sent me by email/text/message.

  • For those who book and attend at least one session, the data I hold includes:

    (a) Basic information such as name, email address, phone number

    (b) Information that you give me as part of the work we do together

    (c) Records of what interventions that I use (or potentially do not use) in our sessions

    (d) Emails, texts and/or messages that are sent between us

    (e) Information sent from any third party, eg GP, insurance company, EAP

  • Some of the information that you give me may fall under the definition of special category of data as defined by the General Data Protection Regulation. I rely on your specific consent to hold this data. The data is primarily used to enable me to provide therapy for you.

  • Other than this, data is not shared with anyone, except possibly your GP in the circumstances detailed in circumstances discussed when we first meet, and for any reasons covered by the Requirements for Disclosure which are detailed and discussed when we first meet.

  • I have a supervisor with whom I discuss clients anonymously, so your name or other information which may cause you to be identifiable will be withheld during supervision.

  • If I am incapacitated due to death or injury, my supervisor will access your name and contact information solely for the purpose of informing you and ensuring continuation of care.

  • Details of where data is held:

    (a) Any emails sent between us are held in a password-protected email account to which only I have access.

    (b) Any text messages sent between us are held on a password-protected mobile phone to which only I have access.

    (c) Typed notes or recordings are held on a password-protected computer to which only I have access.

    (d) Paper notes are held in a locked safe to which only I have access.

  • Your data is kept for 8 years. The length of time is based on the requirements of my insurance company. After this time any paper records are shredded and computer records permanently deleted.

  • I take the security of data seriously and if there is any breach of data securityI will give full details to the Information Commissioners Office and any person affected within 72 hours of the breach and do all possible to minimise any potential impact.

  • You have rights with regards to the data held:

    (a) The right of access. I will provide you with all data I hold on you as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).

    (b) The right to rectification. If any data I hold is incorrect, just let me know and I will correct it as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).

    (c) The right to erasure. If you wish me to erase your data just let me know and I will delete any computer records and shred any paper records as soon as I can following a request (and definitely within 30 days, unless this is impossible due to holidays or illness).

    (d) the right to restrict processing. This would usually be a stop-gap measure before correction of any errors or before erasure.

    (e) the right to data portability. This might apply if you want your notes sent to another therapist for example, but it is likely that the easiest solution would come under the right to access, ie I would send the data to you.

    (f) The right to object to: (i) processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling).I do not engage in these things. (ii) direct marketing.(iii) processing for purposes of scientific/historical research and statistics. For this, you must provide grounds for your objection. (iii) automated decision making and profiling. I don’t engage in automated decision making or profiling.

If you have any questions, please do not hesitate to get in touch.