PRIVACY NOTICE (Data Processing)

Who we are and how we process your personal data

Caroline and Craig Stevens comply with their obligations under the General Data Protection
Regulation (GDPR) by keeping personal data up to date; by storing (and destroying it)
securely; by not collecting or retaining excessive amounts of data; by protecting personal data
from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate
technical measures are in place to protect personal data.

We use your personal data for the following purposes
To deliver the services that clients have requested;
To contact those clients as necessary in accordance with the services they have requested;
To contact clients via surveys to ascertain their opinions on the service they received from us;
To maintain our own accounts and records.
N.B. In the event that our recorded data is utilised for research purposes, our own supervision
or for the instruction or tuition of students, all such data will be sufficiently anonymised to the
extent that individual clients cannot be identified. Should a client indicate that their data should
not be used for these purposes, we would refrain from using that data.

Individual client data will never be passed to a third party without the express consent of the
respective client, always provided that such confidentiality is neither inconsistent with the
therapist’s own safety or that of the client, the client’s family members or other members of the
public, nor in contravention of any legal action or legal requirement.
In accordance with my need to maintain the possibility of access to client data as a result of
returning clients or those who may wish to lodge a complaint in respect of our professional
services to either our professional body or our insurers (i.e. in all cases perhaps after a long
period of time has elapsed), we retain client data for a minimum period of 7 years. For clients
under the age of 18, data will be retained until their 25th birthday.

Our Lawful Basis for processing client personal data
The client has given clear consent for me to process their personal data for a specific purpose.
Further, the processing is necessary for both my client’s and my own legitimate interests.

Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to
your personal data:
The right to request a copy of your personal data which Caroline and Craig Stevens hold about
The right to request that Caroline and Craig Stevens correct any personal data if it is found to
be inaccurate or out of date;

The right to request your personal data is erased where it is no longer necessary for Caroline
and Craig Stevens to retain such data;
The right to withdraw your consent to the processing at any time;
The right to request that the data controller provide the data subject with his/her personal data
and where possible, to transmit that data directly to another data controller, (known as the right
to data portability), (where applicable) [N.B. This only applies where the processing is based
on consent or is necessary for the performance of a contract with the data subject and in either
case the data controller processes the data by automated means].
The right, where there is a dispute in relation to the accuracy or processing of your personal
data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable) [N.B. This only
applies where processing is based on legitimate interests (or the performance of a task in the
public interest/exercise of official authority); direct marketing and processing for the purposes
of scientific/historical research and statistics]
The right to lodge a complaint with the Information Commissioners Office. (See below).
Complaints Notice
The client has the right to complain to the Independent Commissioner’s Office (ICO) if they
think there is a problem with the way we are handling their data