Privacy Policy

1. Who I Am

Swynnerton Therapy is a sole practitioner psychotherapy practice operated by Richard Swynnerton, UKCP Registered Psychotherapist. I am the data controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

If you have any questions about this privacy policy or how your personal data is handled, please contact me at: 79 Sebright Road, High Barnet, Hertfordshire, EN5 4HP, or via the contact form at swynnertontherapy.co.uk.

2. What Personal Data I Collect

I may collect and process the following personal data:

Contact information: your name, email address, and telephone number, provided when you use the contact form on this website or communicate with me directly.

Clinical information: information you share during therapy sessions, including personal history, presenting difficulties, and any other information relevant to your therapy. Brief session notes are kept as part of your clinical record.

Website usage data: this website uses cookies and may collect anonymised usage data via Squarespace, the platform on which it is built, and via Google Analytics. Please see Section 8 for more information on cookies.

3. Why I Collect Your Data and My Legal Basis

To respond to your enquiry: when you contact me via the website form or by other means, I process your contact details in order to respond. The legal basis for this is legitimate interests.

To provide therapy: I process clinical information in order to provide psychotherapy services. The legal basis for processing this data is the performance of a contract (the therapeutic agreement between us) and, where relevant, the provision of health care services.

Special category data: the clinical information I hold about you is "special category data" under UK GDPR, meaning it requires an additional legal basis beyond the one above. I process this data on the basis of the provision of health and social care treatment (Article 9(2)(h) UK GDPR), and in reliance on my professional duty of confidentiality as a UKCP Registered Psychotherapist (Schedule 1, Data Protection Act 2018).

To meet my professional and legal obligations: as a UKCP Registered Psychotherapist, I am required to maintain clinical records and to work within a framework of professional supervision. The legal basis for this processing is legal obligation and legitimate interests.

4. How Long I Keep Your Data

In line with UKCP guidance, clinical records for adult clients are retained for a period of seven years following the end of therapy, after which they are securely destroyed. Contact information provided via the website enquiry form, where therapy does not commence, is deleted within six months of the initial enquiry.

5. Who I Share Your Data With

Your personal data is treated with the strictest confidentiality. As a general principle, I do not share your information with third parties. There are two exceptions to this:

Clinical supervision: as required by the UKCP, I work within a framework of professional supervision. Client material may be discussed with a clinical supervisor for the purpose of maintaining the quality and safety of the therapeutic work. This is done anonymously wherever possible.

Legal and safeguarding obligations: in exceptional circumstances, I may be required to share information without your consent, for example, where there is a serious risk of harm to you or to others, or where I am required to do so by law. Where possible, this would be discussed with you beforehand.

6. Your Rights

Under UK GDPR, you have the following rights in relation to your personal data:

The right to access: you may request a copy of the personal data I hold about you.

The right to rectification: you may ask me to correct inaccurate or incomplete data.

The right to erasure: in certain circumstances, you may ask me to delete your personal data. Please note that my professional obligations may require me to retain clinical records for the period described above.

The right to restrict processing: you may ask me to limit the way I use your data in certain circumstances.

The right to object: you may object to the processing of your data where I rely on legitimate interests as my legal basis.

To exercise any of these rights, please contact me using the details in Section 1. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

7. Data Security

I take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. Clinical notes are stored securely. Electronic communications are subject to the inherent security limitations of email and internet transmission, and you should be aware of this when contacting me online.

8. Cookies

This website is built on the Squarespace platform, which uses cookies to operate and improve the site. Cookies are small files placed on your device when you visit a website. Squarespace may use cookies for functional purposes (such as remembering your preferences) and for anonymised analytics.

This site also uses Google Analytics, which places its own cookies to help me understand, anonymously, how visitors use the site. You can control cookie settings through your browser.

For more information on how Squarespace handles data, please refer to the Squarespace Privacy Policy at squarespace.com/privacy. For more information on Google Analytics, please refer to Google's Privacy Policy at policies.google.com/privacy.

Google Analytics is provided by Google, a company based in the United States. This means some data may be transferred outside the UK. Where this occurs, Google relies on standard contractual safeguards recognised under UK data protection law to protect your data. Squarespace may similarly process some data outside the UK, under its own equivalent safeguards; please refer to the Squarespace Privacy Policy above for further detail.

9. Changes to This Policy

I may update this privacy policy from time to time. Any changes will be posted on this page with an updated date. I encourage you to review this policy periodically.

10. ICO Registration

Swynnerton Therapy is registered with the Information Commissioner's Office as a data controller. Registration reference: ZA426255.