This notice explains what information South Downs Therapy Collective (SDTC) holds about people who enquire, apply or work with us; why we hold it; who may see it; and the choices and rights you have. We want professional relationships to begin with openness. That includes being clear about what we need to know, what we do not need to know, and where information may need to move when responsibility is shared.

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At a glance

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• We ask for information that helps us understand professional suitability, verify essential requirements, arrange placements or working agreements, match clients thoughtfully, make payments and hold the responsibilities SDTC has accepted.

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• Applications, references, financial information, DBS information and sensitive personal information are not made generally available across the Collective.

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• Qualified therapists and trainees remain responsible for the clinical records they create. SDTC does not routinely read or copy those records.

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• Where a complaint, safeguarding concern, serious incident, continuity issue or professional concern involves SDTC, we may hold a separate and proportionate organisational record.

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• We do not sell your information or use automated decision-making to decide whether you can join or continue working with SDTC.

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1. Who this notice applies to

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This notice applies to people who enquire or apply to join SDTC, qualified therapists, trainee and newly qualified therapists, placement applicants, supervisors and other practitioners working through the Collective. It also applies to former applicants and practitioners while SDTC still has a lawful reason to keep information about them.

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It is separate from the Client Privacy Notice. Client information remains governed by the client notice and, for the detailed clinical record, by the privacy arrangements of the therapist who created it. There are moments when therapist and client information overlap; this notice explains how SDTC approaches those moments.

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2. Who is responsible for your information?

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South Downs Therapy Collective Ltd is the data controller for the therapist and applicant information described in this notice. This means SDTC decides why that information is used and how it is handled.

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

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• Email: hello@southdownstherapycollective.co.uk

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

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3. Information we may hold

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The information we hold depends on the stage and nature of your relationship with SDTC. It may include:

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Identity and contact information. Your name, address, email address, telephone number and other information needed to identify or contact you.

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Application and interview information. Application forms, CVs, reasons for applying, professional history, interview notes, references, suitability decisions and related correspondence.

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Professional and placement information. Qualifications, course and training stage, professional membership or registration, accreditation, insurance, supervision arrangements, training-provider approval, fitness-to-practise confirmation, DBS status where relevant, competence, experience, special interests, availability and scope of practice.

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Working-relationship information. Agreements, onboarding records, policy acknowledgements, availability, client-allocation information, supervision and placement arrangements, professional development, relevant meeting records, correspondence, departures and continuity arrangements.

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Profile and public information. An agreed biography, photograph, therapeutic approach, qualifications, interests, fees, availability and other information intended for clients or the public.

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Financial information. Bank details, invoices, session and payout records, fees, expenses and accounting information.

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Feedback, complaints and governance information. Client or colleague feedback, complaints, safeguarding matters, data incidents, continuity issues, professional concerns, decisions, agreed actions and information needed for a fair response.

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Technical and communication information. Emails, form submissions, document metadata and information generated through the website, Google Workspace, payment or other administrative systems.

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4. Sensitive information

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We do not need a complete account of your private life. Sensitive information may nevertheless become relevant where you request an adjustment, tell us about something affecting your capacity or availability, or where a safeguarding, complaint, fitness-to-practise or legal matter arises. This may include information about health, disability, ethnicity, religion, sexuality or other matters protected as special category information under data protection law.

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We will only use this information for the purpose for which it is relevant. Depending on the circumstances, our additional legal condition may be explicit consent, legal claims, health or social care, or a substantial-public-interest condition such as safeguarding. We will consider whether the information is genuinely necessary rather than collecting it simply because it might be useful later.

If you ask for a reasonable adjustment, we will usually discuss with you what needs to be known and who needs to know it. The aim is to support participation without turning a personal disclosure into general organisational information.

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5. DBS checks and criminal-offence information

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Information about criminal convictions, allegations and DBS checks is subject to separate and particularly careful legal rules. Even a DBS result showing no convictions is criminal-offence information for data-protection purposes.

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SDTC will only request or consider a DBS check where the role and level of check are appropriate, legally available and connected to a clear safeguarding or placement purpose. This is most likely to be relevant to trainee or low-cost work where the agreed role or training provider requires it. A DBS check is not treated as a routine requirement for every practitioner simply because they are a therapist.

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Where a check is relevant, we usually record only what is needed to evidence the process, such as the type of check, date, certificate number, Update Service status where used, the decision reached and any review date. We do not normally keep a copy of the certificate. If certificate information must exceptionally be retained while a decision, dispute or safeguarding audit is completed, it will normally be securely destroyed within six months of the decision unless there is a specific lawful reason for longer retention.

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We will identify both an ordinary lawful basis and an applicable condition in Schedule 1 of the Data Protection Act 2018 before processing criminal-offence information. Depending on the purpose, this may include safeguarding children or individuals at risk. Access will be tightly limited and the information will not be used for an unrelated purpose.

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6. How we receive information

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Most information comes directly from you through an enquiry, application, CV, interview, onboarding process, profile form, agreement, invoice, supervision or professional conversation.

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We may also receive or verify information through:

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• referees you have identified;

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• your training provider, course, placement contact or clinical supervisor;

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• professional bodies, public registers, accreditation organisations or insurers;

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• a DBS or umbrella-body process where a check is lawfully required;

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• clients, therapists, supervisors or others where feedback, complaints, safeguarding or professional concerns arise;

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• and public professional information, such as a directory entry or website, where checking it is relevant and proportionate.

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We will normally tell you before contacting referees, a training provider or another person for a professional check. If information is received through a complaint, safeguarding matter or professional concern, we will aim to tell you enough to understand and respond fairly, unless doing so would create a serious risk, compromise another person’s rights or frustrate a lawful process.

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7. Why we use information

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Enquiries and applications. To respond, consider professional and relational fit, make fair selection decisions and communicate the outcome.

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Professional and placement checks. To confirm qualifications, membership, registration, insurance, references, training-provider approval, supervision, DBS status where relevant, and whether the proposed work is within your competence and the service’s scope.

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Working agreements and onboarding. To prepare agreements, introduce SDTC’s expectations and systems, and maintain a clear record of what has been agreed.

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Client matching and continuity. To understand your availability, competence, interests, limits and capacity, support thoughtful matching, and respond if therapy needs to pause, end or transfer.

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Payments and finance. To receive invoices, calculate and make therapist payouts, maintain accounting and tax records, and resolve payment questions.

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Profiles and public communication. To help prospective clients understand who you are and whether you might be a good fit, using information agreed for publication.

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Supervision, placements and professional development. To support trainees and practitioners, meet agreed course or placement requirements, and respond to learning or support needs.

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Complaints, safeguarding and professional concerns. To understand what has happened, hear relevant perspectives, protect safety and continuity, respond fairly, and decide what responsibility, repair, support or action may be needed.

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Legal and organisational responsibilities. To meet accounting, insurance, data-protection, safeguarding, contractual and other lawful responsibilities and to protect the legitimate interests of clients, practitioners and SDTC.

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Some information is necessary if you want to work through SDTC. If you do not provide evidence of required qualifications, professional membership, insurance, references, training approval or a lawfully required DBS check, we may be unable to progress or continue the arrangement. You do not have to provide information that is genuinely optional, although declining may limit that particular use.

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Decisions about applications, allocations, concerns or continuing involvement are made by people. We do not use profiling or solely automated decision-making for these decisions.

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8. The legal reasons we rely on

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• Applications, interviews, references and professional checks
  We rely on steps taken before entering a contract and our legitimate interests in selecting suitable practitioners.
  Where needed, we rely on explicit consent, legal claims, or another relevant special-category condition. For criminal-offence information, we rely on an applicable condition under Schedule 1 of the Data Protection Act 2018.

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• Agreements, onboarding, allocations, supervision and communication
  We rely on our contract with you and our legitimate interests in operating a careful collective and therapy service.
  Where sensitive information is genuinely necessary, this may include health or social care, safeguarding, explicit consent, or another appropriate condition.

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

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• Profiles and agreed public information
  We rely on our contract with you and our legitimate interests in maintaining your core professional profile.
  We will ask for consent for genuinely optional promotional uses. Where an optional use includes sensitive information, we will seek explicit consent.

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• Complaints, safeguarding, data incidents, professional concerns and legal matters
  We rely on legitimate interests, legal obligations where they apply, and the need to establish, exercise or defend legal claims.
  Depending on the situation, this may also involve conditions relating to legal claims, safeguarding, health or social care, substantial public interest, or criminal-offence information.

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9. Who may see or receive information

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Access is based on role and need, not general membership of the Collective. Applications, references, bank details, private professional information, DBS information and sensitive personal information are not shared across the therapist community.

Depending on the purpose, information may be seen or received by:

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• the Collective Lead and Clinical Lead;

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• an unconflicted independent practitioner where a concern involves both leads or independence is otherwise needed;

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• a clinical or placement supervisor and, for trainees, the relevant training provider or course contact;

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• a client, but only the agreed public profile and the limited professional or practical information needed for matching, therapy, continuity or a fair complaint response;

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• referees, professional bodies, registers, insurers or DBS providers where a relevant check or confirmation is being made;

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

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• technology providers that process information for SDTC, including website, email, forms, document storage, payment and accounting services;

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• and a safeguarding service, police, court, regulator, professional body, insurer or another appropriate organisation where sharing is required by law or necessary and proportionate for safeguarding, public protection, a complaint or a legal matter.

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Where a complaint or concern is raised about you, you will normally be given enough information to understand the substance and respond. We may need to protect the identity, privacy or safety of another person, and we cannot promise to disclose every part of an internal or third-party record. We will distinguish confidentiality from secrecy and explain the limits as clearly as we can.

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10. Client information and clinical records

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Qualified therapists are responsible for the clinical records they create. Trainees are also responsible for creating and maintaining appropriate clinical records within the arrangements agreed with SDTC, their supervisor and training provider. Those arrangements must include what happens to records when a placement ends.

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SDTC does not routinely access, read or copy full clinical notes. It maintains separate records for enquiries, matching, administration, payments, feedback, complaints and any safeguarding, serious-risk, continuity or governance matter that has been brought centrally and gives SDTC a genuine reason to act.

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Relevant information or a limited part of a clinical record may need to be requested where this is necessary and proportionate for safeguarding, a serious concern, a complaint, continuity of care, insurance or a legal requirement. This does not turn the therapist’s whole clinical record into an SDTC record. Any overlap should be handled carefully, with the client’s and therapist’s privacy both considered.

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11. Profiles, photographs and public information

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A public therapist profile is part of how clients understand their choices. If you join SDTC, we will work with you to agree accurate information about your experience, therapeutic approach, interests, professional status, fees and availability. The core profile is used as part of the working arrangement; additional promotional content, testimonials or uses outside that core purpose should be agreed separately.

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You can ask for inaccurate information to be corrected and for your profile to be updated or removed. Removing a profile may affect our ability to offer referrals if public visibility is part of the agreed arrangement. When you leave, SDTC will remove the current profile within a reasonable period, although we cannot fully control search-engine caches, archived pages, screenshots or copies kept elsewhere.

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12. 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 professional, applicant and governance records are kept within restricted SDTC systems. Access is normally limited to the Collective Lead and Clinical Lead, or another specifically authorised person where the role requires it.

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We use access controls, passwords, account security and careful sharing practices, and we avoid unnecessary copies. Private applications, references, DBS information, bank details and identifiable governance records are not stored in community folders, ordinary group messages or meeting notes intended for wider access.

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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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Some providers may store or make information accessible outside the UK. Where this is a restricted international transfer, we use an approved route such as UK adequacy regulations or appropriate contractual safeguards. You may contact us for more information about safeguards relevant to your information.

 

13. How long we keep information

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

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• an unsuccessful application: 12 months after the recruitment or placement decision;

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• a successful application: relevant application and onboarding information becomes part of the practitioner or placement record;

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• a current therapist, trainee or supervisor: for the duration of the relationship, with key contractual, professional and governance records normally kept for six years after it ends;

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• financial 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 or serious-risk records: reviewed after six years and retained longer only where there is a continuing safeguarding, clinical, legal, insurance or professional reason;

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• a DBS certificate or copy: not normally retained; if exceptionally needed after a decision, usually no longer than six months;

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• a minimal DBS status record: kept only while needed to evidence the relevant recruitment, placement or safeguarding decision and reviewed when the relationship ends;

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• and public profile information: updated or removed when no longer accurate, agreed or relevant, subject to historic copies outside SDTC’s control.

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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. A decision to retain information longer should have a clear reason and a further review date.

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14. 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 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 are important but not always absolute. We may need to retain information for a contract, legal claim, safeguarding, accounting, insurance or another lawful reason, and we must also protect the rights and privacy of clients, referees, complainants and other people.

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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.

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15. 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 will try to understand the concern, explain our reasoning and take responsibility where something needs to change.

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Email: hello@southdownstherapycollective.co.uk

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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16. Changes to this notice

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We will review this notice at least annually and sooner if SDTC changes its application process, service model, systems, placement arrangements, supervision structure, payment arrangements or use of information. The current version should be provided or linked wherever we ask applicants or practitioners to give us personal information.n only be held honestly if relevant information is allowed to move. Our aim is not to accumulate files or monitor therapists unnecessarily. It is to know what we need to know, protect what has been entrusted to us, and be transparent when safety, fairness or shared responsibility requires information to be used.