Privacy Notice

This privacy notice tells you what to expect us to do with your personal information.

The “too long, didn’t read” (TLDR) version

I keep your contact details on password protected devices (my phone and laptop). I only use them to contact you regarding your therapy, not for marketing or any other reason.

Any records I keep are stored securely and retained only as long as the law and my professional body require. I generally don’t take or keep notes about anything you tell me in our sessions in the normal course of things.

The long and the short of it is: if you have any questions or concerns about what data I have about you, you have a right to ask me about it, to see it and have me destroy it.

Here follows the very long, will read version (VLWR), which I include to comply with UK legislation. It covers very remote eventualities which will in all likelihood never happen.

This privacy notice tells you what to expect us to do with your personal information.

• Contact details

• What information we collect, use, and why

• Lawful bases and data protection rights

• Where we get personal information from

• How long we keep information

• Who we share information with

• How to complain

Contact details

Telephone

07707743618

Email

paul@paulnewmancounselling.uk

What information we collect, use, and why

We collect or use the following information to provide patient care, services, pharmaceutical products and other goods:

• Name, address and contact details

• Gender

• Pronoun preferences

• Date of birth

• Next of Kin details including any support networks

• Emergency contact details

• Health information (including medical conditions, allergies, medical requirements and medical history)

• Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)

• Payment details (including card or bank information for transfers and direct debits)

• Records of meetings and decisions

• Call recordings

• Information about income and financial needs for funding or personal budget support

• Details of personal issues affecting quality of life

We also collect the following special category information to provide patient care, services, and other goods. This information is subject to additional protection due to its sensitive nature:

• Racial or ethnic origin

• Political opinions

• Religious or philosophical beliefs

• Trade union membership

• Health information

• Sex life information

• Sexual orientation information

We collect or use the following information for safeguarding or public protection reasons:

• Name, address and contact details

• Emergency contact details

• Health information (including medical conditions, allergies, medical requirements and medical history)

• Information about care needs (including disabilities, home conditions, dietary requirements and general care provisions)

• Relevant information from previous investigations

• Records of meetings and decisions

We also collect the following special category information for safeguarding or public protection reasons. This information is subject to additional protection due to its sensitive nature:

• Racial or ethnic origin

• Religious or philosophical beliefs

• Sex life information

• Sexual orientation information

We collect or use the following personal information to comply with legal requirements:

• Name

• Contact information

• Health and safety information

• Any other personal information required to comply with legal obligations

• Safeguarding information

We also collect the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:

• Racial or ethnic origin

• Political opinions

• Religious or philosophical beliefs

• Health information

• Sex life information

• Sexual orientation information

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details

• Addresses

• Purchase or service history

• Audio recordings of private or staff only areas

• Customer or client accounts and records

• Correspondence

We also collect the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:

• Racial or ethnic origin

• Political opinions

• Religious or philosophical beliefs

• Trade union membership

• Health information

• Sex life information

• Sexual orientation information

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.

• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.

• Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.

• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.

• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.

• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.

• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests - we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

• Therapeutic Data Processing As a therapist, processing personal information serves core clinical functions including assessment, diagnosis, treatment planning, progress monitoring, coordination with healthcare providers, billing for services, and emergency contact protocols. For pharmaceutical referrals, this enables appropriate prescription management and adverse reaction tracking. Under GDPR Article 6(1)(b) and 9(2)(h), processing is necessary for providing health care, social care, or treatment, and management of health\/social care systems. This creates a dual basis: contractual necessity for provision of agreed services and legitimate interest in delivering safe, effective care. The clinical benefits of accurate data collection are substantial. Complete history prevents harmful drug interactions, enables tailored interventions, and supports continuity across sessions. Without complete information, treatment quality deteriorates and client safety is compromised. Operationally, contact details allow appointment confirmations, cancellations, and urgent communications. Billing information ensures sustainable service delivery. From a safety perspective, emergency contacts and medical alerts protect clients during crises, while treatment notes document progress and prevent relapse. Limited data sharing with prescribing physicians reduces medication errors and improves outcomes. However, these benefits must be weighed against privacy concerns. The primary risk involves potential privacy intrusion, unauthorized disclosure, data breaches, or improper third-party access. To mitigate these risks, therapists apply minimal data principles, maintain strict confidentiality, implement encryption and access controls, anonymize data where possible, enforce secure storage, limit retention periods, and require client consent for each sharing instance with third parties. Collection must be limited to what is strictly necessary for identified purposes. Clients retain rights to access their records, request corrections, withdraw consent except where clinically mandated, and know who accesses their data. Processing duration is restricted to clinical necessity plus statutory retention requirements, typically seven years minimum for medical records. Crucially, therapists cannot prioritize institutional needs over client welfare. Data collection requires informed consent explaining exactly what is gathered, why, and how it protects client interests rather than therapist convenience. Transparency and control remain with the client throughout the therapeutic relationship. Legitimate interest in therapeutic data processing exists because effective mental health treatment fundamentally depends on accurate information exchange. The substantial benefit to client health outcomes outweighs controlled, mitigated risks when standard confidentiality safeguards are applied. This balance protects both vulnerable clients and professional accountability, ensuring that data processing serves the client\'s best interests above all other considerations.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

• Recognised legitimate interests - our pre-approved purpose for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods:

We need to share personal information with a public authority or another organisation because they need it for their public tasks or official functions (the ‘public task disclosure response condition’)., We need to safeguard national security, protect public security, or for defence reasons (the ‘national security, public security and defence condition’)., We need to respond to, or deal with, an emergency event or situation (the ‘emergencies condition’)., We need to prevent, detect, or investigate a crime, including the apprehension and prosecution of offenders (the ‘crime condition’)., We need to protect the physical, mental or emotional well-being of people who need extra support, or to protect them from harm or neglect (the ‘safeguarding condition’).

• Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

•

• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

Our lawful bases for collecting or using personal information for safeguarding or public protection reasons are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

• Safeguarding and Public Protection As a therapist, processing personal information for safeguarding and public protection purposes serves critical protective functions including risk assessment, mandatory reporting obligations, duty to warn third parties, child and adult protection referrals, and prevention of serious harm. Under GDPR Article 6(1)(c) and 9(2)(b), processing is necessary for compliance with legal obligations relating to employment, social security, and social protection law, as well as for protecting vital interests where the client cannot give consent. The benefits of collecting and using information for safeguarding are substantial and life-saving. Accurate assessment of risk enables timely intervention when clients pose danger to themselves or others, preventing suicide, self-harm, violence, or abuse. Mandatory reporting to authorities protects vulnerable individuals including children, elderly persons, and dependent adults who may suffer harm. Duty to warn obligations allow potential victims to take protective measures when threats are credible. Early identification of abuse patterns enables coordinated multi-agency responses that break cycles of exploitation. These interventions serve both the immediate client and broader public safety interests. However, these benefits must be carefully balanced against privacy concerns. The primary risks involve breaching confidentiality without client knowledge, potential damage to therapeutic alliance, stigma from disclosure, and unintended consequences of third-party involvement. To mitigate these risks, therapists apply proportionality assessments, disclose only minimum necessary information, notify clients when legally permissible, document decision-making processes thoroughly, seek supervision or legal counsel when uncertain, and maintain clear boundaries between therapeutic and protective roles. Information collection must be limited to what is strictly necessary for identified safeguarding purposes. Clients retain rights to understand why disclosure occurred, receive copies of reports filed where applicable, and access records of safeguarding actions taken. Processing duration aligns with statutory requirements for protected person files and ongoing risk monitoring periods. Crucially, therapists cannot prioritize self-protection or convenience over genuine safeguarding needs. Disclosure requires careful justification demonstrating that harm prevention clearly outweighs confidentiality obligations. Transparency occurs whenever legally possible, and clients participate in decision-making except where involvement would increase danger. Legitimate interest in safeguarding data processing exists because professional and legal duties to protect life and prevent serious harm override typical confidentiality expectations when credible threats emerge. The substantial benefit to client, family member, and public safety outweighs controlled, mitigated privacy risks when standard ethical safeguards are applied. This balance protects vulnerable individuals from preventable harm while maintaining professional integrity and legal compliance.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

• Recognised legitimate interests - our pre-approved purpose for collecting or using personal information for safeguarding or public protection reasons:

We need to share personal information with a public authority or another organisation because they need it for their public tasks or official functions (the ‘public task disclosure response condition’)., We need to safeguard national security, protect public security, or for defence reasons (the ‘national security, public security and defence condition’)., We need to respond to, or deal with, an emergency event or situation (the ‘emergencies condition’)., We need to prevent, detect, or investigate a crime, including the apprehension and prosecution of offenders (the ‘crime condition’)., We need to protect the physical, mental or emotional well-being of people who need extra support, or to protect them from harm or neglect (the ‘safeguarding condition’).

• Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

Our lawful bases for collecting or using personal information to comply with legal requirements are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

• Compliance with Legal Requirements: As a therapist, processing personal information for legal compliance serves essential regulatory functions including record-keeping obligations, taxation and billing requirements, insurance verification, mandatory reporting statutes, court orders, subpoenas, professional licensing standards, and audit trails for regulatory bodies. Under GDPR Article 6(1)(c), processing is necessary for compliance with a legal obligation to which the controller is subject, creating a clear lawful basis independent of consent. The benefits of collecting and using information for legal compliance are fundamental to maintaining professional integrity and accountability. Accurate documentation ensures adherence to statutory retention periods, enabling verification of care quality during inspections or investigations. Billing records support tax compliance and prevent fraud. Insurance verification protects clients from unexpected costs while ensuring proper reimbursement for covered services. Court-ordered disclosures fulfill judicial obligations and support legal proceedings. Professional licensing requirements mandate certain documentation to demonstrate competent practice. These compliance activities protect both clients and the broader healthcare system from fraud, malpractice, and unprofessional conduct. However, these benefits must be weighed against privacy concerns. The primary risks involve collecting information beyond therapeutic necessity, potential unauthorized secondary uses, extended data retention beyond required periods, and increased exposure through regulatory sharing. To mitigate these risks, therapists apply strict relevance filters, retain data only for legally mandated durations, implement secure storage systems, limit access to authorized personnel, and document all compliance-related disclosures with justification. Information collection must be limited to what legislation expressly requires. Clients retain rights to understand why information is collected for legal purposes, receive notification when legally permitted, access records of compliance activities involving their data, and challenge unnecessary or excessive collection practices. Processing duration is restricted to statutory minimums where possible, with regular reviews to eliminate obsolete records. Crucially, therapists cannot prioritize organizational convenience over client privacy. Legal compliance obligations require careful distinction between genuine statutory mandates and perceived administrative burdens that lack legal foundation. Transparency occurs wherever legally possible, and clients receive notice of compliance activities except where disclosure would violate legal prohibitions. Legitimate interest in legal compliance data processing exists because professional practice fundamentally operates within regulatory frameworks that mandate certain documentation and reporting. The substantial benefit to legal accountability, fraud prevention, and systemic integrity outweighs controlled, mitigated privacy risks when standard confidentiality safeguards are applied. This balance protects clients from institutional abuse while ensuring therapists meet their legal duties without compromising core therapeutic values.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

• Recognised legitimate interests - our pre-approved purpose for collecting or using personal information to comply with legal requirements:

We need to share personal information with a public authority or another organisation because they need it for their public tasks or official functions (the ‘public task disclosure response condition’)., We need to safeguard national security, protect public security, or for defence reasons (the ‘national security, public security and defence condition’)., We need to respond to, or deal with, an emergency event or situation (the ‘emergencies condition’)., We need to prevent, detect, or investigate a crime, including the apprehension and prosecution of offenders (the ‘crime condition’)., We need to protect the physical, mental or emotional well-being of people who need extra support, or to protect them from harm or neglect (the ‘safeguarding condition’).

• Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

• Recognised legitimate interests - our pre-approved purpose for collecting or using personal information for dealing with queries, complaints or claims:

We need to share personal information with a public authority or another organisation because they need it for their public tasks or official functions (the ‘public task disclosure response condition’)., We need to safeguard national security, protect public security, or for defence reasons (the ‘national security, public security and defence condition’)., We need to respond to, or deal with, an emergency event or situation (the ‘emergencies condition’)., We need to prevent, detect, or investigate a crime, including the apprehension and prosecution of offenders (the ‘crime condition’)., We need to protect the physical, mental or emotional well-being of people who need extra support, or to protect them from harm or neglect (the ‘safeguarding condition’).

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: Dealing with Queries, Complaints, or Claims: As a therapist, processing personal information for handling queries, complaints, or claims serves essential accountability and dispute resolution functions including case review, grievance documentation, communication logs, incident investigation, mediation records, and regulatory complaint filings. Under GDPR Article 6(1)(f), processing is necessary for the purposes of the legitimate interests pursued by the controller, provided those interests are not overridden by the rights and freedoms of the client. The benefits of collecting and using information for query and complaint resolution are substantial for both individual clients and the therapeutic profession. Accurate documentation enables fair investigation of concerns, ensuring that client voices are heard and addressed appropriately. Communication records facilitate accurate reconstruction of events during disputes. Incident investigation allows corrective action when service failures occur. Mediation documentation supports resolution without escalating to formal regulatory bodies. Regulatory complaint filings protect the profession\'s integrity while validating legitimate grievances. These processes maintain trust in therapeutic services, improve quality through feedback loops, and provide recourse when clients experience harm or dissatisfaction. However, these benefits must be balanced against privacy concerns. The primary risks involve extended data retention beyond resolution periods, potential re-traumatization when reviewing sensitive complaints, unauthorized sharing with unrelated third parties, and power imbalances that may discourage clients from filing genuine grievances. To mitigate these risks, therapists apply purpose limitation principles, retain data only for complaint resolution plus statutory limitation periods, restrict access to designated personnel, anonymize where possible, and ensure independent oversight for serious disputes. Information collection must be limited to what is strictly necessary for resolving the specific query or complaint. Clients retain rights to access complaint records concerning them, receive updates on investigation progress, receive outcomes and remedies offered, withdraw consent for non-mandatory elements, and file complaints with independent oversight bodies if dissatisfied. Processing duration ends once the matter is resolved plus applicable statute of limitations periods. Crucially, therapists cannot prioritize reputational protection over client rights. Complaint handling requires impartiality, ensuring that administrative convenience never outweighs fair consideration of client concerns. Transparency occurs throughout the process, and clients participate actively in resolution discussions except where safety or legal barriers prevent participation. Legitimate interest in complaint-related data processing exists because professional accountability requires mechanisms to address service failures and client grievances. The substantial benefit to fairness, quality improvement, and professional integrity outweighs controlled, mitigated privacy risks when standard confidentiality safeguards are applied. This balance protects clients from unaddressed harm while enabling therapists to learn from mistakes and maintain public trust in mental health services.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

• Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

• Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

Where we get personal information from

• Directly from you

• Other health and care providers

• Third parties:

o Anyone the client consents to supply information on their behalf.

• Brief notes may be taken by the therapist as a reminder of what took place during a session.

How long we keep information

No longer than a period of three years after therapy has ended.

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

Who we share information with

Others we share personal information with

• Organisations we need to share information with for safeguarding reasons

• Emergency services

• Organisations we’re legally obliged to share personal information with

Duty of confidentiality

We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:

• you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);

• we have a legal requirement (including court orders) to collect, share or use the data;

• on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);

• If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or

• If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.

How to complain

If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

Email: paul@paulnewmancounselling.com

Post: 172 RAEBURN RD, SHEFFIELD, S. YORKS, S14 1SD

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

ICO Head Office

4th Floor, No.3 Circle Square

5 Hawkshaw Street

Manchester

M1 7BL

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

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