Therapy depends on trust. This notice explains what information South Downs Therapy Collective (SDTC) holds about you, why we hold it, who may see it and the choices you have. It applies to adults who enquire about or receive therapy through SDTC, and to anyone who contacts us on their behalf.

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At a glance:

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• SDTC holds the information needed to respond to enquiries, consider suitability and matching, arrange and administer therapy, take payments, hear feedback and complaints, and act where it has a genuine responsibility for safety or continuity.

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• Your therapist holds the detailed clinical record of your therapy. SDTC does not routinely receive or read those notes.

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• Information moves between your therapist and SDTC only where there is a clear reason. We aim to share the minimum that is needed and to involve you wherever it is safe and reasonably possible.

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• We do not sell your information, use therapy information for marketing, or use automated decision-making to decide whether therapy is right for you or which therapist you should see.

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• Our forms and email accounts are not monitored as an urgent-help or crisis service.

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1. Who is responsible for your information?

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South Downs Therapy Collective Ltd is the data controller for the information SDTC holds. This includes enquiry and matching information, administrative and payment records, feedback and complaints, and any safeguarding, serious-risk, continuity or governance record that SDTC has a genuine reason to create.

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You can contact us about this notice or about information held by SDTC:

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• Email: hello@southdownstherapycollective.co.uk

• Address: South Downs Therapy Collective Ltd, 10 Station Parade, Eastbourne, East Sussex, BN21 1BE

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Your therapist is professionally responsible for the therapy they provide and for the clinical record they create. In most arrangements, they act as a separate data controller for that record. Their own privacy information should explain how they keep and use it. If you are unsure whether SDTC or your therapist holds something, please ask us and we will help you find the right route.

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2. The boundary between SDTC and your therapist

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The therapeutic relationship is central. SDTC supports the conditions around it: how you first make contact, how matching happens, payments and practical administration, continuity if something changes, and a route for feedback or concerns.

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Your therapist’s clinical record remains separate. It may include brief notes about the work, clinical decisions, risk, safeguarding, attendance and agreed plans. SDTC does not ask for routine updates about what you talk about in therapy, and difficult or uncertain therapy does not by itself create an SDTC record.

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Your therapist may bring information to SDTC where the Collective has something real to do. This could include a significant safeguarding concern, immediate or developing danger, a decision to limit confidentiality, a serious interruption to therapy, a concern that the work may no longer be within the service’s scope, a complaint, a serious information incident, or another matter requiring coordinated action.

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When this happens, SDTC creates only the organisational record it needs. We do not duplicate the full clinical record. The record should be factual, proportionate and clear about what was known, what was decided, what was shared and why.

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3. Information SDTC may hold

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What we hold depends on how you contact us and what support you are seeking. It may include:

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• your name, age or date of birth, contact details and, where relevant, an emergency contact;

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• the information you give through an enquiry, the Help Me Choose questionnaire, email, telephone or an introductory conversation;

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• what you hope therapy may help with, previous experience of therapy, preferences, access needs, availability, location and whether you would like online or in-person sessions;

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• health, disability, neurodivergence, identity, sexuality, culture, relationships, trauma, medication, diagnosis or other personal circumstances where you choose to share these or they are relevant to suitability, matching or safety;

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• information about self-harm, suicide, harm from others, harm to others or safeguarding where this is relevant;

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• which therapist was considered or allocated, whether therapy began or ended, appointments, attendance, cancellations, payments and refunds;

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• feedback, concerns, complaints and correspondence with SDTC;

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• a limited organisational record where a safeguarding, serious-risk, continuity, complaint, incident or legal matter has been brought to SDTC;

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• and basic technical information generated through our website, forms, email, payment and administrative systems.

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Some of this is called special category information under data protection law because it concerns matters such as health, ethnicity, religion, sexuality or sex life. We treat this information with additional care.

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4. How we receive information

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Most information comes directly from you. You may give it through our website, the Help Me Choose questionnaire, email, telephone, a payment system, a client agreement, a feedback form or a conversation with us.

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We may also receive relevant information from your therapist, someone making an enquiry or referral on your behalf, an emergency contact, a GP or other health professional, a safeguarding service, an emergency service, a training provider or another organisation involved in responding to a concern. We will normally tell you about information received from elsewhere unless you already know, it would be unsafe to do so, or the law allows or requires us not to.

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If someone else enquires, refers or pays for you, that does not give them a general right to information about your therapy. We will take care to understand what you have agreed can be shared.

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5. Why we use information

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Enquiries and matching. To understand what you are looking for, consider whether SDTC may be suitable, and suggest a therapist whose competence, availability and way of working may fit what matters to you.

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Arranging and administering therapy. To introduce you to a therapist, manage agreements, appointments, payments, cancellations and refunds, and keep the wider client journey clear.

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Continuity of care. To respond if you want to change therapist, your therapist becomes unavailable, the work needs to pause or end, or another form of support may be more appropriate.

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Safety and safeguarding. To consider and respond where there is a serious concern about your safety or someone else’s, while respecting your autonomy and using the least intrusive response compatible with safety.

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Feedback and complaints. To understand your experience, respond fairly, consider repair or learning, and take action where SDTC has a responsibility.

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Finance and organisational duties. To maintain payment, accounting, insurance and other records SDTC needs to operate responsibly.

Learning and improvement. To notice themes and improve the service. Wherever possible, we use information that has been anonymised so that it no longer identifies you.

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Questions about safety or personal circumstances are there to support careful human judgement, not to reduce you to a score or a risk category. A “yes”, “unsure” or “prefer not to say” response does not automatically make you unsuitable for therapy. If you do not provide basic contact information, we may be unable to reply. Leaving other questions unanswered may limit how confidently we can consider suitability or matching, but we will not make an automated decision about you.

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6. The legal reasons we rely on

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• Responding to enquiries, matching and arranging therapy
  We rely on steps taken before entering a contract, our contract with you where relevant, and our legitimate interests in running a careful therapy service. Where sensitive information is involved, this is usually because it is needed to provide or manage health or social care under a duty of confidentiality. Sometimes we will ask for your explicit consent.

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• Payments, refunds, tax and accounting
  We rely on our contract with you and legal obligations. We do not usually need sensitive information for this, unless a financial record also reveals it.

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• Safety, safeguarding and urgent situations
  We rely on legitimate interests, legal obligations where they apply, and vital interests in rare emergencies. Where sensitive information is involved, this may be for health or social care, vital interests, safeguarding, or substantial public interest reasons where the legal requirements are met.

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• Complaints, insurance and legal matters
  We rely on legitimate interests, legal obligations where they apply, and the need to establish, exercise or defend legal claims. This may involve relevant health or social care information, depending on the issue.

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• Sharing information at your request or for something genuinely optional
  We rely on your consent where this is the appropriate basis. Where sensitive information is involved, we will seek explicit consent where required.

 

7. Confidentiality and sharing information

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We begin from confidentiality. Information is shared only where there is a clear purpose, and we aim to share no more than is reasonably needed.

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Depending on the situation, information may be shared with:

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• a therapist we are considering for you, so they can decide whether they have the competence and capacity to work with you;

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• your allocated therapist;

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• the Collective Lead, Clinical Lead or an unconflicted independent practitioner where SDTC needs to make or review an organisational decision;

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• a clinical or placement supervisor and, for trainee work, a training provider where this is genuinely needed for safe practice, placement governance or continuity;

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• payment, accounting, insurance, legal or professional advisers who need limited information for their role;

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• technology providers that process information for SDTC, such as our website, email, document-storage, form, payment and accounting providers;

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• or a GP, NHS or emergency service, safeguarding service, police, court, professional body, insurer or other appropriate organisation where you have agreed, the law requires it, or disclosure is necessary and proportionate for safety, safeguarding, a complaint or a legal matter.

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Wherever it is safe and reasonably possible, we will speak with you before identifiable information is shared outside the ordinary running of the service. There are circumstances where we may need to act without your agreement, particularly to protect a child or adult at risk, prevent serious harm, respond to an emergency, comply with law or deal with a legal claim. We will still consider your wishes, the possible consequences of sharing or not sharing, and whether a less intrusive option is available.

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Therapists discuss their work in confidential clinical supervision. Identifying details are kept to a minimum wherever possible. Supervision is part of responsible therapeutic practice and is separate from SDTC routinely receiving your clinical record.

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8. Where information is kept and how it is protected

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SDTC currently uses services including Wix, Google Workspace, Google Forms, Google Drive and Google Sheets, together with payment and accounting providers. Sensitive organisational records are kept within restricted SDTC systems, with access limited to the people who need them. They are not placed in community-meeting notes, peer-supervision records, ordinary group messages or shared folders that do not have an appropriate reason to contain them.

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We use access controls, passwords, account security and careful sharing practices, and we avoid unnecessary copies. No digital system is entirely risk-free. If personal information is lost, disclosed or accessed in error, we will contain and assess what happened.

We will inform the Information Commissioner’s Office where the legal reporting threshold is met and tell affected people without undue delay where the breach creates a high risk to them.

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Email and online forms are convenient, but they are not suitable for urgent help. Please avoid sending more sensitive information by email or text than is needed for the purpose.

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9. How long we keep information

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We keep identifiable information only while there is a clear reason to do so. Our usual periods are:

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• an enquiry that does not become therapy: 12 months after the last contact;

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• an enquiry that becomes therapy, and SDTC’s administrative client record: five years after the final SDTC contact or the end of therapy;

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• payment, tax and accounting records: six years from the end of the relevant financial year;

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• complaint records: six years after the complaint closes;

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• safeguarding and serious-risk records: reviewed after six years and kept longer only where there remains a clear safeguarding, clinical, legal, insurance or professional reason;

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• and genuinely anonymised service information: it may be kept for longer because it no longer identifies you.

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Open complaints, safeguarding matters, serious incidents, insurance issues, legal matters or unresolved financial questions may require related records to be kept beyond the usual period. Any decision to keep an SDTC record longer should have a clear reason and a further review date.

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Your therapist sets the retention period for their own clinical record in line with their professional, insurance and data-protection responsibilities. Please refer to their privacy information for that period.

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10. Your rights

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Depending on the circumstances and the legal basis being used, you may have the right to:

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• ask whether SDTC holds personal information about you and receive a copy;

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• ask us to correct inaccurate or incomplete information;

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• ask us to delete information where there is no continuing lawful reason to keep it;

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• ask us to restrict how information is used in some circumstances;

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• object to processing based on legitimate interests;

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• receive certain information in a portable format where the right to data portability applies;

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• withdraw consent where we are relying on it;

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• and complain to the Information Commissioner’s Office.

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These rights matter, but some are not absolute. For example, we may need to retain information for a legal claim, safeguarding, accounting or another lawful reason, and we must also protect other people’s privacy. We will explain our reasoning if we cannot do exactly what you ask.

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Please send requests to hello@southdownstherapycollective.co.uk. We may need enough information to confirm your identity and understand what you are asking for. We will normally respond without undue delay and within one month. If your request concerns your therapist’s separate clinical record, we may direct you to them or help you make contact.

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11. Urgent help

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SDTC is not an emergency, crisis or out-of-hours service. Our forms and email accounts are not continuously monitored. If you or someone else is in immediate danger, call 999. For urgent health or mental-health support, contact NHS 111, your GP or the appropriate local urgent service. Please do not rely on a form submission or email to alert us to an emergency.

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12. Questions or concerns about privacy

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If something about the way your information has been handled does not feel right, please contact us. We would rather understand the concern and respond to it than leave you carrying it alone.

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Email: hello@southdownstherapycollective.co.uk

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You also have the right to complain to the Information Commissioner’s Office. Visit ico.org.uk/make-a-complaint or telephone 0303 123 1113.

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13. Changes to this notice

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We will review this notice at least annually and sooner if SDTC changes its services, systems, working arrangements or use of information. The current version should be available wherever we ask clients or prospective clients to provide personal information.

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A final note

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Privacy is not simply an administrative requirement. It is part of creating the conditions in which people can speak honestly and feel respected. We will not promise that information can never be shared, because there are moments when care, safety or law require action. We can promise to treat those moments seriously: to think carefully, share proportionately, involve you wherever we can, and remain accountable for the choices we make.