Privacy Policy / Privacy Notice:

1. The type of personal information collected is as follows:

  • Name, email address, telephone number: collected at assessment.
  • Payment details: generated during the therapy process.
  • Therapy contract: paper copy or electronic copy collected after the second session. Held on password protected computer or locked filing cabinet
  • Notes – minimal notes on sessions are kept.  These notes are brief, anonymised, relevant and stored securely in a locked filing cabinet;
  • Written communications – including emails and any text messages exchanged with the therapist.
  • Some special category data may be collected such as medical history.

2. How we get the personal information and why we have it.

The personal information we process is provided to us directly by you for one of the following reasons:

  • To effectively and safely provide therapy services
  • To administer payment details
  • For your safety in case of emergency

3. This personal information is provided to us directly by you for one of the following reasons:

  • Provision of social care and the provision of health care – to effectively and safely provide therapy services
  • Performance of the contract – applicable during therapy, to ensure that the service contracted for is delivered.
  • Comply with financial regulations – to administer payment and tax requirement.

4. Under the UK General Data Protection Regulation (UK GDPR), the lawful bases relied on for processing this information are:

  • We have a contractual obligation.
  • We have a legitimate interest.
  • I have a legal obligation (such as tax requirements).

5. In certain circumstances we may share this information with:

  • Relevant authorities (such as mental health crisis team or GP) in exceptional circumstances, should the therapist have reason to believe that the safety of the client or others is at risk.
  • Coroner, Judge, tribunal, by law or order of a court.
  • During supervision with a clinical supervisor within confidentiality framework.
  • HMRC if requested (not notes). HMRC have a duty of confidentiality, please refer to HMRC for further details.
  • Secure (Passcode protected) Tide Bank invoicing and payment App (not notes).
  • Or by the client themselves following discussion and consideration if requested

6. How your personal information is stored:

Your information is securely stored. We keep notes securely for 6 years as advised by the UKCP. Electronic data is stored securely on password or passcode protected computer or phone. After 6 years your information will be disposed of by deletion, shredding or burning.

7. Under data protection law, you have rights including:

  •  Your personal information is deleted (right to deletion). However, there is no absolute right to be forgotten, and notes will not be destroyed as set out in my common law right to legal defence. The retention of notes is an ethical requirement of the UKCP.
  • The use of your personal information is limited (restriction of processing). This must be agreed before therapy starts and this may inhibit the delivery of therapy.
  • The processing of your personal information is stopped (objection to processing). This must be agreed before therapy starts and this may inhibit the delivery of therapy.
  • (Right to access) to request a copy of your personal information. This request will be reasonably discussed and considered. Notes may not be provided if it is not considered appropriate or in the client’s therapeutic interests.  
  • (right to data portability) – You have the right to ask that personal information you gave us is transferred to another organisation, in certain circumstances. This request will be reasonably discussed and considered. Notes may not be provided if it is not considered appropriate or in the client’s therapeutic interests.  
  • Please contact markswhite1001@gmail.com if you wish to make a request.

8. Concerns and complaints:

If you have any concerns about our use of your personal information, you can make a complaint to us at markswhite1001@gmail.com. More information or a complaint can be made to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, Helpline number: 0303 123 1113, ICO website: https://www.ico.org.uk

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