Last
updated 29 October 2026
This
privacy statement explains how I collect, process, store, and protect your personal data in accordance with General Data Protection Regulation (GDPR) and the ethical frameworks of my registering
bodies.
Who is the data
controller?
The Data
Controller is Sarah Smith practicing in the UK and online. If you have any questions regarding this Privacy Statement or wish to exercise any of your data protection rights, please contact me
directly through the enquiry form.
What Personal Data I
Collect
I collect personal and special category
data to provide safe, ethical, and effective services. This includes personal identifiers (your full name, contact details, date of birth, home address, and emergency contact details, and any
relevant medical details) . I also collect and record brief clinical notes, psychometric assessments, session attendance dates, and basic billing and payment transactions.
Lawful basis for collecting data
Under Article 6 of the GDPR, the lawful basis for processing your personal identifiers is contractual necessity. This means I
require this information to establish, manage, and deliver the services you have requested. Under Article 9 of the GDPR, my processing of special category data (such as health-related notes and
assessments) is justified under the provision of health or social care and treatment, supplemented by your explicit signed consent.
Secure Storage and Data Systems
Your electronic clinical records, intake
documentation, and messaging are securely stored and encrypted on a GDPR-compliant practice management system and/or encrypted email. I do not store credit card details locally, and all electronic
payment transactions are processed securely through certified, GDPR-compliant third-party financial providers.
Website, Cookies and Contact
Forms
When you browse my practice website, I
may collect basic technical data such as IP addresses, geographical locations, browser types, and page-interaction analytics. This data is collected using standard cookies to help me improve site
navigation and monitor service performance. If you submit an inquiry through my website contact form, the details you input (typically your name, email, and brief query) are encrypted and transmitted
securely to me to facilitate a response. These details are only retained to process your initial request and are deleted if you choose not to proceed with therapy.
How long I keep your
records
I retain your clinical records and
personal data for a period of five years following your final session or as required by my professional indemnity insurance guidelines. (I do not work with U18, but any such records are retained for
five years until after they reach the age of maturity). After the retention period, all records are securely destroyed.
Recording Sessions
To safeguard the privacy,
confidentiality and integrity of our work together, the recording of sessions (including audio, video, screen captures, or automated AI transcription tools) by either party is strictly prohibited
without prior written consent. Any uploading onto any social media platform is strictly prohibited as are online reviews on my business pages where your confidential
data may be visible. This policy applies to both online and in-person sessions to maintain a safe and trusting therapeutic environment.
Confidentiality, Data Sharing and Safeguarding
Your information is treated with strict
professional confidentiality. I will not share your personal data with third parties unless required by law or in accordance with standard clinical exceptions and I will endeavour to discuss with you
in advance if possible. These exceptions include: if there is a severe risk of harm to yourself or another person, where legal requirements mandate disclosure (such as acts of terrorism, drug
trafficking, or safeguarding issues), or as part of professional clinical supervision where client cases are presented anonymously.
I will encourage you to seek further help, or ask that I act on your behalf by contacting your GP or an emergency contact of your choosing. To access
support especially in an emergency call 999, NHS 111 (option 2) or Samaritans 116 112.
Please note that any communication
channels used (such as email, internet, Zoom, FaceTime, WhatsApp, Signal or other platforms) are subject to the confidentiality and privacy limitations of those specific service providers. Therefore,
to keep your data safe I ask you to agree to use either the provided management space or contact me direct only using my secure
email.
Your
rights
Under GDPR 2018, 2025, you have the right to: see the information I hold about you (including your notes, by making formal request);
have inaccurate information corrected; ask for your information to be erased (with the exceptions above or where the processes of health-related data is required for professional legal defence,
insurance compliance, or statutory clinical duties); restrict or object to processing; withdraw consent at any time; and complain to the Information Commissioner’s Office (ico.org.uk
0303 123 1113).
Changes
I may update this policy from time to time and dated accordingly.