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My Lawful Basis for Processing Your Information
Under the UK General Data Protection Regulation (UK GDPR), I must have a lawful basis for collecting and using your personal information.
Initial Enquiries
If you contact me to enquire about therapy, I process your personal information because it is necessary to take steps at your request before entering into a therapeutic contract. This may include your name, telephone number, email address and any information you choose to share about what has brought you to therapy.
This information is used solely to communicate with you about your enquiry and to determine whether I am the right therapist for your needs.
If I believe another therapist or service would be better placed to support you, I may suggest alternative options. I will never share your information with another professional without your knowledge and permission.
If you decide not to begin therapy with me, I will securely delete your personal information within a reasonable period unless there is a legal reason for me to retain it.
During therapy
Once we begin working together, I process your personal information because it is necessary for the performance of our therapeutic agreement (Article 6(1)(b) UK GDPR).
As a psychotherapist, I also process Special Category Data relating to your physical and mental health. This is processed under Article 9(2)(h) UK GDPR, which permits the processing of health information where it is necessary for the provision of health care.
In some circumstances, I may also retain or process information where it is necessary for the establishment, exercise or defence of legal claims under Article 9(2)(f) UK GDPR, or where I have a legal obligation to do so.
Where I ask for your consent for a specific purpose—for example, to contact another healthcare professional on your behalf—I will always explain what you are consenting to, and you are free to withdraw that consent at any time. Withdrawing consent will not affect any processing that has already taken place lawfully.
I will ask you to complete a client information form. This helps me provide safe and effective care and may include:
Throughout our work together, I will use your contact details only to communicate with you about your therapy, such as arranging, confirming or changing appointments, or sharing information directly relevant to our work together.
I will never use your personal information for marketing purposes, nor will I sell or share your information with third parties.
How Long I Keep Your Information
I keep your personal information only for as long as is necessary to fulfil my professional, ethical, legal and insurance responsibilities.
In line with current professional practice for independent psychotherapists, I normally retain adult client records, including my brief clinical notes, for seven years after therapy has ended. This reflects guidance from the British Association for Counselling and Psychotherapy (BACP), professional insurers and relevant legal limitation periods.
Financial records are retained for the period required by HM Revenue & Customs (HMRC).
Once the relevant retention period has expired, your records are confidentially destroyed or permanently and securely deleted.
If you ask me to erase your information before the end of the retention period, I will carefully consider your request. However, there may be circumstances where I am legally, ethically or professionally required to retain certain information, including where records are needed to comply with legal obligations, satisfy insurance requirements, or establish, exercise or defend legal claims.
Website and Cookies
If you visit my website, limited information may be collected automatically through the use of cookies.
Cookies help the website function effectively and, where enabled, may provide anonymous information about how visitors use the website so that it can be improved over time.
Where website analytics are used, they are configured to collect anonymised information wherever possible and are not used to identify you personally.
You can control or disable cookies through your web browser settings, although doing so may affect the functionality of some areas of the website.
If my website contains links to external websites or services, those organisations have their own privacy policies, and I encourage you to read them as I am not responsible for their privacy practices.
Consent
In most circumstances, I do not rely on consent as the legal basis for processing your personal information because processing your information is necessary to provide psychotherapy safely and ethically.
However, there are occasions where I may ask for your explicit consent. These might include:
Where I ask for your consent, you have the right to withdraw it at any time. This will not affect any processing that has already taken place lawfully before consent was withdrawn.
Clinical Records
As part of my professional practice, I maintain brief clinical notes following each therapy session. My clinical notes are intended as professional memory aids to support safe and effective therapy. They are written solely to support continuity of care and to meet my professional, ethical and legal responsibilities.My notes are deliberately concise and are not a verbatim record or transcript of our conversations. Wherever possible, they contain only the information necessary to support your ongoing therapy and are written with respect for your privacy and dignity.
How Your Information Is Stored
I use KIKU, a secure practice management system designed specifically for counsellors and psychotherapists, to manage client records.
KIKU enables me to securely store:
KIKU employs appropriate technical and organisational security measures, including encrypted data transmission, password protection and two-factor authentication to help safeguard your personal information.
Access to your records is restricted to me unless access is required for technical maintenance or data recovery under strict confidentiality arrangements.
Where I hold any paper records, they are stored securely in a locked cabinet with access restricted to me.
Email, Telephone and Text Messages
I use email, telephone and text messages only for matters relating to your appointments or our therapeutic work.
I encourage clients not to send highly sensitive or lengthy therapeutic information by email or text wherever possible, as these methods of communication cannot be guaranteed to be completely secure.
Where important clinical information is received by email or text message, I may make a brief note within your clinical record and securely delete the original message where appropriate.
Routine administrative emails and text messages are deleted periodically once they are no longer required.
Online Therapy
Where therapy is provided online or by telephone, I take reasonable steps to ensure your privacy and confidentiality.
Sessions are conducted in a private and confidential environment using secure communication platforms.
While I choose platforms that use appropriate encryption and security measures, no internet-based technology can ever be guaranteed to be completely secure. By choosing online therapy, you acknowledge this small but unavoidable risk.
I will never record online sessions unless we have discussed this together beforehand and you have given explicit written consent.
Clinical Supervision
As a Registered Member of the British Association for Counselling and Psychotherapy (BACP), I participate in regular professional clinical supervision.
Supervision is an essential part of safe and ethical practice and helps ensure that I provide the highest possible standard of care.
During supervision I may discuss aspects of our therapeutic work. Wherever possible, identifying information is removed or minimised, and my supervisor is bound by the same professional standards of confidentiality and data protection.
Your identity is always protected.
Clinical Will
As part of responsible professional practice, I have a Clinical Will in place.
In the unlikely event of my death or becoming unable to practise, a trusted professional colleague acting as my Clinical Executor may be given limited access to essential client contact information solely for the purpose of informing clients, offering appropriate guidance regarding ongoing support and ensuring that confidential records are managed appropriately.
My Clinical Executor is a qualified therapist who is bound by professional confidentiality, UK GDPR and the BACP Ethical Framework.
They will ensure that any paper records are confidentially destroyed and that digital records are securely managed or deleted in accordance with professional, ethical and legal requirements.
How Long I Keep Your Information
I keep your personal information only for as long as is necessary to fulfil my professional, ethical, legal and insurance responsibilities.
In line with current professional practice for independent psychotherapists, I normally retain adult client records, including my brief clinical notes, for seven years after therapy has ended. This reflects guidance from the British Association for Counselling and Psychotherapy (BACP), professional insurers and relevant legal limitation periods.
Financial records are retained for the period required by HM Revenue & Customs (HMRC).
Once the relevant retention period has expired, your records are confidentially destroyed or permanently and securely deleted.
If you ask me to erase your information before the end of the retention period, I will carefully consider your request. However, there may be circumstances where I am legally, ethically or professionally required to retain certain information, including where records are needed to comply with legal obligations, satisfy insurance requirements, or establish, exercise or defend legal claims.
Third-Party Services
To provide my services safely and efficiently, I use a small number of carefully selected third-party providers who process personal information on my behalf. Wherever I work with another organisation, I ensure that appropriate data processing agreements and security measures are in place.
KIKU Practice Management
I use KIKU, a secure practice management system designed specifically for counsellors and psychotherapists.
KIKU is used to securely manage client records, appointments, consent forms, invoices, correspondence and my brief clinical notes.
KIKU has been developed to comply with UK GDPR requirements and uses encrypted data transmission, secure hosting, password protection and two-factor authentication to help protect your personal information.
Payments
If you pay for sessions electronically, your payment will be processed through secure banking services or a secure payment provider such as Stripe (where applicable).
I do not store your debit or credit card details.
To comply with HM Revenue & Customs (HMRC) requirements, I retain financial records only for the period required by law.
Email and Video Platforms
Where we communicate by email or meet online, I use reputable service providers that incorporate appropriate security measures.
Although these providers employ encryption and security protocols, no internet-based communication can ever be guaranteed to be completely secure. I therefore recommend that particularly sensitive information is discussed during therapy sessions rather than by email.
Website and Cookies
If you visit my website, limited information may be collected automatically through the use of cookies.
Cookies help the website function effectively and may also provide anonymous information about how visitors use the site so that improvements can be made.
If Google Analytics or similar website analytics are used, this information is anonymised and is not used to identify you personally.
You can choose to disable cookies through your web browser settings, although doing so may affect the functionality of some parts of the website.
Where my website contains links to other websites, those organisations have their own privacy policies and I am not responsible for their content or data handling practices.
Who I Share Your Information With
Your personal information remains confidential.
I will never sell your information or share it for advertising or marketing purposes.
Information will only be shared where:
Wherever possible, I will discuss any proposed disclosure with you beforehand unless doing so would increase the risk of harm or prevent appropriate safeguarding action.
Your Rights
Under the UK General Data Protection Regulation (UK GDPR), you have a number of important rights regarding your personal information.
These include the right to:
Please note that these rights are not absolute. There may be occasions where I am legally or professionally required to retain certain information despite a request for deletion.
Accessing Your Information
You may request a copy of the personal information I hold about you at any time.
I will normally respond within one month, in accordance with UK GDPR.
In most circumstances there is no charge for making a Subject Access Request.
If I believe disclosure of any part of your clinical record may cause serious harm to you or another person, I will consider this carefully in accordance with relevant legislation and professional guidance before releasing information.
Data Security
Protecting your information is an important part of my professional practice.
I take appropriate technical and organisational measures to reduce the risk of unauthorised access, loss, misuse or accidental disclosure.
These measures include:
Data Breaches
Although every reasonable precaution is taken to protect your information, no system can ever be completely risk free.
If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, I will follow the procedures required under UK GDPR.
Where necessary, I will notify the Information Commissioner's Office (ICO) without undue delay and, where required, within 72 hours of becoming aware of the breach.
If the breach is likely to present a high risk to you, I will also inform you as soon as reasonably practicable and explain the steps being taken to address the situation.
Raising Concerns
I hope that if you ever have concerns about how I handle your personal information, you will feel able to discuss them with me first so that we can try to resolve them together.
If you remain dissatisfied, you have the right to make a complaint to the Information Commissioner's Office (ICO).
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website: www.ico.org.uk
Contact Details
If you have any questions about this Privacy Notice or about how your information is managed, please contact:
Terri
Respair Psychotherapy and Somatics
Email: terri@respairtherapy.co.uk
Website: www.respairtherapy.co.uk
ICO Registration Number: ZB716158
Registered Member of the British Association for Counselling and Psychotherapy (BACP)
Registration Number: 407000
Changes to this Privacy Notice
From time to time I may update this Privacy Notice to reflect changes in legislation, professional guidance or the way I manage my practice.
The most recent version will always be available on request and, where applicable, on my website.
Respair Psychotherapy and Somatics