Privacy policy

We understand how important your privacy is. We take care to maintain your confidentiality in accordance with current data protection laws (GDPR, 2018) and the ethical guidelines of The Health Care Professions Council. This privacy policy will inform you as to how we protect your personal data and any confidential information when you visit our website, when you complete our contact form, when you access therapy, consultation, supervision or other services from The Relational Practice. It also informs you about your privacy rights and how the law protects you and your rights.

Data Controller

Dr Ruth Butterworth and Dr Davy Evans (trading in partnership as The Relational Practice) are the data controller for the purposes of the Information Commissioners Office (ICO), and are responsible for your personal data, referred to as “The Relational Practice”, “we”, “us” or “our” throughout this policy. If you have any questions or concerns please contact us on hello@therelationalpractice.co.uk.

The personal information we collect about you

Personal information (or data), is any identifiable information about an individual. It does not include data that has been anonymised or that is not identifiable.

We may collect, use, store and transfer different kinds of personal information about you, as follow:

Identity data (e.g. forename, surname, title, date of birth)
Contact data (e.g. address, email address, telephone number)
Financial data (e.g. bank account or payment card details)
Transaction data (e.g. details of payments you make or receive and details of products or services you purchase from us)
Profile data (e.g. survey responses)
Technical data (collected through cookies, e.g. equipment, browsing actions, patterns)
Usage data (e.g. how you use our website)
Marketing and Communications data (e.g. communication preferences)
Special or sensitive data (e.g. information about the difficulties you are experiencing)

For therapy clients

In order to be able to fulfil our duty of care to you, in your initial consultation session, your psychologist will ask you for contact information for your GP and elected Emergency Contact person. These details will also be stored securely along with your personal data.

For professional supervision

In order to be able to fulfil our duty of care to you, in your initial supervision, your supervisor will ask you for contact information for your line manager. These details will also be stored securely along with your personal data.

How is your personal data collected?

Direct interactions (e.g. by filling in forms, using our services, or corresponding with us)
Subscribe to our services or products
Give us feedback or contact us
Automated technologies or interactions (e.g. through Cookies)
Third parties or publicly available sources (e.g. Google Analytics)

How do we use your personal data?

We will only use your personal data when the law allows us to. This might include:

To decide whether we can offer you a particular service
Where we need to comply with a legal obligation
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Generally we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending any third party marketing communications to you via email or other means. You have the right to withdraw consent to communication and other data use at any time by contacting us.

We will only share your personal information with other professionals with your consent unless there is a legal reason that we must comply with.

We do not transfer your personal data outside the UK.

The purposes we may use your data for are:

To register you as a customer. We will use your identity, contact and any required special or sensitive information. Our legitimate interest for using this is to perform a contract with you.
To provide agreed clinical services to you. We will use your identity, contact, and any required special or sensitive information. Our legitimate interest for using this is to carry out our duty of care to you.
To process and deliver services to you, manage payments and fees and collect fees payable to us. We will use your identity, contact, financial, transaction, marketing and communication and any required special or sensitive information. Our legitimate interest for using this is to perform a contract with you, and recover debts due to us.
To manage our relationship with you, which will include notifying you about changes to our terms or policies, or to ask you to respond to a survey. We will use your identity, contact, profile and marketing and communication information. Our legitimate interest for using this is to perform a contract with you, to comply with any legal obligation, to keep our records updated and to study how customers use our services.
To administer and protect our business and this website. We will use your identity, contact and technical information. Our legitimate interest for using this is run our business and prevent fraud, and to comply with any legal obligation.
To deliver relevant website content and advertisements and measure or understand the effectiveness of the advertising we serve to you. We will use your identity, contact, profile, usage, marketing and communications and technical information. Our legitimate interest for using this is to develop our services and business.
To use data analytics to improve our website, products and services. We will use your technical and usage information. Our legitimate interest for using this is to keep our website and services updated and relevant.
To make suggestions and recommendations to you about goods and services. We will use your identity, contact, technical, usage, profile, marketing and communications information. Our legitimate interest for using this is to develop our products and services and grow our business.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use on our website, please see our Cookie policy.

Change of purpose

We will only use your personal information for the purposes for which we collect it unless we reasonably consider that we to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or financial requirements. We may retain your personal information for a longer period in the event of a complaint or dispute.

For therapy or supervision, please note that we will need to keep a record of your name and reference number for seven years after the end of your therapy or supervision, so that we can respond effectively to any potential requests regarding your therapy or supervision notes. After this time your data will be deleted from our records.

To determine the appropriate retention period for non-therapy and non-supervision related personal information, we consider the amount and nature of the information, the potential risk of harm from unauthorised disclosure of your personal information, the purpose for which we use your information, and any other legal or financial requirements.

Therapy

Please see The Relational Practice Client Agreement. When you book your first session with us you will be asked to provide a signature to confirm that you consent to the storage and processing of your personal data for the purposes of providing therapeutic or supervisory services.

You are entitled to withdraw this consent at any time and can do so by emailing hello@therelationalpractice.co.uk.

Supervision

Please see The Relational Practice Supervision Agreement.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We collect and store therapy and supervision notes on a secure, encrypted and password protected drive.

All of our email accounts use the secure GSuite server and are double password protected. If you send an email to your psychologist’s email address, it will only be accessible by the two registered partners of The Relational Practice – Dr Davy Evans and Dr Ruth Butterworth.

Your rights

Any personal data retained by The Relational Practice is kept in accordance with the GDPR, 2018.

Under these guidelines you have the following rights

1. The right to request access to your data

You can request to view the information that we hold about you (contact details, appointment logs etc.) at any time. If during therapy or supervision you would like to see your session notes, please make this request by emailing hello@therelationalpractice.co.uk. Should you require a copy of your notes after your therapy or supervision has come to an end you can make this request by emailing hello@therelationalpractice.co.uk.

2. The right of rectification

At any point during your time using our service or during the seven years thereafter, while we retain your records, you have the right to request amendments to your contact details or session notes. This right can be exercised either by speaking directly to your psychologist or contacting us in writing.

3. The right to be forgotten

You can request that we delete and confidentially destroy the information that we hold about you and your sessions at any time. This request can be made by contacting us at hello@therelationalpractice.co.uk.

4. The right to object to processing your personal information where our legitimate interests impact on your fundamental rights and freedoms.

Instances where we would not be able to comply with your request are as follows:

a) It is necessary for us to retain these records in order to continue providing an effective service

b) We are compelled to retain these records by a Court of Law

c) We require these records in order to establish, exercise or defend legal claims

Breaches of data protection

In the event of any breach of our data protection policies, we will notify you and the Information Commissioner’s Office (ICO) within 72 hours and will seek to rectify this immediately.

Raising concerns

Should you have any concerns about our data protection practices, you can raise these directly with us. You can also notify the Information Commissioner’s Office.