Introduction
Your privacy is very important to me and you can be confident that your personal information will be kept safe and secure and will only be used for the purpose it was given to me. I adhere to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (the GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
This privacy notice tells you what I will do with your personal information from initial point of contact through to after your therapy or supervision has ended, including:
- Why I am able to process your information and what purpose I am processing it for
- Whether you have to provide it to me
- How long I store it for
- Whether there are other recipients of your personal information
- Whether I intend to transfer it to another country,
- Whether I do automated decision-making or profiling, and
Your data protection rights
I am happy to chat through any questions you might have about my data protection policy and you can contact me via email. ‘Data controller’ is the term used to describe the person/ organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is me.
I am registered with the Information Commissioner’s Office [registration number ZA389260]
My phone number is 07801 729528
My email address is shelley@shelleycarrtherapy.com
The Information I Collect
To provide therapy and supervision, I collect and store information relevant to your care, including:
- Personal identification details – name, date of birth, contact details.
- Background and assessment information – relevant personal history, goals for therapy, GP details, and referral source.
- Therapy and supervision records – session notes reflecting key themes, emotions, and experiences (not verbatim transcripts).
- Administrative data – appointment history, correspondence, invoices, and payment records.
- Sensitive (special category) data – information about your mental health, relationships, and emotional experiences shared during therapy or supervision.
My lawful basis for holding and using your personal information
The GDPR states that I must have a lawful basis for processing your personal data. I process your data under the following lawful bases set out in the UK GDPR:
- Contract (Article 6(1)(b)) – to deliver psychotherapy or supervision services as agreed.
- Legitimate Interests (Article 6(1)(f)) – to maintain clinical records and ensure safe, effective practice.
- Legal Obligation (Article 6(1)(c)) – for compliance with tax, insurance, or safeguarding requirements.
- Explicit Consent (Article 9(2)(a)) – for processing special category data (mental health information).
You may withdraw your consent at any time, although this may affect my ability to continue providing therapy or supervision.
The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for me processing any special categories of personal information is that it is for provision of health treatment (in this case psychotherapy or supervision) and necessary for a contract with a health professional (in this case, a contract between me and you).
How I use your information
I use your information to:
- Provide psychotherapy or supervision and maintain continuity of care.
- Manage appointments, correspondence, and billing.
- Support clinical reflection and supervision (all identifying details are anonymised in the supervision I undertake to fulil the requirements of my professional body, the NCIP. AEDP (Accelerated Experiential Dynamic Psychotherapy) supervision includes the review of videotaped client sessions and therefore some identifying details will be apparent.)
- Fulfil my legal, ethical, and professional obligations as a psychotherapist and supervisor.
- Maintain required records for audit and accountability.
I use your information in each stage of therapy or supervision as follows:
Initial contact
When you contact me with an enquiry about my psychotherapy or supervision services I will collect information to help me satisfy your enquiry. This will typically include your name, email address, telephone number and emergency contact details. Alternatively, your GP or other health professional may send me your details when making a referral or a parent or trusted individual may give me your details when making an enquiry on your behalf.
If you decide not to proceed I will ensure all your personal data is deleted within 30 days. If you would like me to delete this information sooner, just let me know.
While you are accessing psychotherapy or supervision
Rest assured that everything you discuss with me is confidential. As a psychotherapy client, that confidentiality will only be broken if I have serious concerns about your safety, or if compelled to disclose by a court of law. I will always try to speak to you about this first, unless there are safeguarding issues that prevent this. For supervisees, supervision will be confidential unless something is shared which gives the supervisor cause for concern that someone is at risk of serious harm, or previously raised ethical concerns have not been addressed.
I will keep a record of your personal details to help the therapy or supervision services run smoothly. These details are kept securely on a secure Cloud-based practice management system called WriteUpp and are not shared with any third party. These details typically include your name, telephone number, email address, date of birth, GP details and an emergency contact.
I keep minimal records detailing sessions attended, main themes and therapeutic interventions. I also keep copies of client contracts, signed permission to record sessions (if relevant), assessment forms (if relevant), safety contracts (if relevant) emails and text messages containing relevant information (please see below). These are stored on my practice management system.
If you have been in therapy with me prior to January 2021 then there may be paper records containing client data. I use a paper diary and record client appointments using a code.
Your name and telephone number will also be shared with my professional executor, who will contact you in the event of my death or serious illness. My executor stores this information securely.
Emails and text messages are deleted after being read. If there is relevant information contained in a text message or email, I will copy that information to my practice management system and delete the original message. Emails are not a secure form of communication and may be retained by service providers. It is therefore not advisable to share personally sensitive data that can be recognised as belonging to a particular individual via email.
After therapy or supervision has ended
Once therapy has ended your records will be kept for 7 years from the end of our contact with each other and are then securely destroyed. I am unable to delete your information before this date. The right of erasure under UK General Data Protection Regulation (UK GDPR) Article 17 (Right to Erasure) does not apply if processing is necessary to comply with a legal obligation. I am legally and contractually obliged by my insurance company to keep client records for 7 years following the last occasion on which treatment was given.
Sharing Your Data
Your personal data will not be shared with third parties except in the following circumstances:
- With your explicit consent, e.g. sharing information with your GP or another health professional.
- Where there is a legal or ethical duty to disclose, such as risk of serious harm to yourself or others, safeguarding concerns, or a court order.
- Within clinical supervision, where anonymised material may be discussed to support safe and effective practice. Where videotape is used to review practice, I will request your explicit consent in writing.
I do not share your data for marketing or commercial purposes.
Third party recipients of personal data
I sometimes share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks. In such cases I have carefully selected which partners I work with. I take great care to ensure that I have a contract with the third party that states what they are allowed to do with the data I share with them. I ensure that they do not use your information in any way other than the task for which they have been contracted.
Payment/ financial information
As a small business owner, I am required by law to retain certain financial information, primarily for tax purposes. I keep financial information for 7 years as advised by HMRC. If paying by BACS, your account name or reference (or the name of the person who is paying) may show up on my online or paper bank statements. Banking transactions may be viewed by employees of the bank, my accountant, my financial advisor, and tax officers (HMRC). You have the right to discuss alternative payment options with me.
Your Rights
I try to be as open as I can be in terms of giving people access to their personal information. You have a right to ask me to delete your personal information, to limit how I use your personal information, or to stop processing your personal information. You also have a right to ask for a copy of any information that I hold about you and to object to the use of your personal data in some circumstances. You can read more about your rights at ico.org.uk/your-data-matters.
If I do hold information about you I will:
- give you a description of it and where it came from;
- tell you why I am holding its, tell you how long I will store your data and how I made this decision;
- tell you who it could be disclosed to;
- let you have a copy of the information in an intelligible form.
You can also ask me at any time to correct any mistakes there may be in the personal information I hold about you.
To make a request for any personal information I may hold about you, please put the request in writing addressing it to shelley@shelleycarrtherapy.com. If you have any complaint about how I handle your personal data please do not hesitate to get in touch with me by writing or emailing to the contact details given above. I would welcome any suggestions for improving my data protection procedures.
If you want to make a formal complaint about the way I have processed your personal information you can contact the ICO which is the statutory body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint.
Data Security
I take the security of the data I hold about you very seriously and as such I take every effort to make sure it is kept secure. My practice management system is password protected, as are the devices I use to access the system (desktop and laptop). My computers are never left logged-in and unattended.
Visitors to my website
When someone visits my website I use a third-party company Google LLC to collect standard internet log information and details of visitor behaviour patterns. I do this to find out various things such as the amount of visitors to various areas of the site.
This information is only processed in a way that doesn’t identify anyone. I do not make, nor do I allow Google LLC to make any attempt to find out the identities of those visiting my website.
I use legitimate interests as my lawful basis for holding and using your personal information in this way when you visit my website.
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No user-specific data is collected by me or any third-party. If you fill in a form on my website, that data will be temporarily stored on the web host before being sent to me.
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