Privacy Notice
This privacy notice tells you what to expect me to do with your personal information.
Contact details
Email: hi@scarletma.com
What information I collect, use, and why
I collect or use the following information to provide psychotherapy services:
Name, address and contact details
Pronoun preferences
Date of birth
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)
Insurance policy details, where therapy is funded through insurance
Records of meetings and decisions
I also collect the following special category information to provide psychotherapy services. This information is subject to additional protection due to its sensitive nature:
Health information
I collect or use the following information for safeguarding or public protection reasons:
Name, address and 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)
Records of meetings and decisions
I 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:
Health information
I collect or use the following personal information to comply with legal requirements:
Name
Contact information
Financial information
Any other personal information required to comply with legal obligations
Safeguarding information
I also collect the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:
Health information
I collect or use the following personal information for dealing with queries, complaints or claims:
Names and contact details
Addresses
Purchase or service history
Client accounts and records
Correspondence
I 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:
Health information
Lawful bases and data protection rights
Under UK data protection law, I 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 I 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 me for copies of your personal information. You can request other information such as details about where I get personal information from and who I 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 me 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 me to delete your personal information. Read more about the right to erasure.
Your right to restriction of processing - You have the right to ask me to limit how I 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 I transfer the personal information you gave me to another organisation, or to you. Read more about the right to data portability.
Your right to withdraw consent – When I use consent as my 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, I must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact me using the contact details at the top of this privacy notice.
My lawful bases for the collection and use of your data
My lawful bases for collecting or using personal information to provide psychotherapy services are:
Contract – I have to collect or use the information so I can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legitimate interests - I am collecting or using your information because it benefits you, my practice 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. My legitimate interests are:
I process clients’ personal and health information as necessary to provide safe and appropriate psychotherapy care, maintain accurate clinical records, manage risk, and meet professional and legal obligations; this processing directly benefits clients’ wellbeing and continuity of care, is limited to what is proportionate and necessary, and is protected by strict confidentiality and secure data handling to ensure that clients’ rights and freedoms are not overridden.
In addition, I process health information under the condition that processing is necessary for the provision of health or social care and is carried out by a professional subject to a duty of confidentiality.
For more information on my use of legitimate interests as a lawful basis you can contact me using the contact details set out above.
My lawful bases for collecting or using personal information for safeguarding or public protection reasons are:
Legal obligation – where I am required to share information to comply with safeguarding law.
Vital interests – where processing is necessary to protect someone’s life.
My lawful bases for collecting or using personal information to comply with legal requirements are:
Legal obligation – where processing is necessary to comply with the law.
My lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
Contract – I have to collect or use the information so I can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Where I get personal information from
Directly from you
How long I keep information
7 years after the end of therapy
For more information on how long I store your personal information or the criteria I use to determine this please contact me using the details provided above.
Who I share information with
I may share personal information where necessary and lawful with:
Other health providers (eg GPs and consultants), with your consent where appropriate
Insurance companies, where therapy is funded through insurance
Safeguarding authorities or other relevant public protection bodies
Emergency services
Clinical supervisor (anonymised where possible)
Local authorities or councils
Organisations I am legally obliged to share personal information with
Duty of confidentiality
I am subject to a common law duty of confidentiality. However, there are circumstances where I will share relevant health and care information. These are where:
you’ve provided me with your consent (I have taken it as implied to provide you with care, or you have given it explicitly for other uses);
I 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)
How to complain
If you have any concerns about my use of your personal data, you can make a complaint to me using the contact details at the top of this privacy notice.
If you remain unhappy with how I have used your data after raising a complaint with me, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113