Who we are and how we process your personal data

Deborah Mills and David Grinnell 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 our 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 8 years from the date of the client’s last visit or, if the client is a child, until their 25th birthday, or 26th birthday if the client was 17 when the treatment ended.

Our Lawful Bases for processing client personal data

Processing of client personal data is necessary for the performance of a contract to which the client is party or in order to take steps at the request of the client prior to entering into a contract. Further, the processing of the special category of personal data is necessary for the provision of healthcare.

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 David Grinnell or Deborah Mills holds about you;

The right to request that David Grinnell or Deborah Mills corrects 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 David Grinnell or Deborah Mills 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
(see https://ico.org.uk/concerns/handling/).