Privacy Notice

Who I am

Nick Spinks Psychotherapy is the private psychotherapy practice of Dr Nick Spinks. For the purposes of UK data protection law, Dr Nick Spinks is the data controller and is responsible for the personal information processed by the practice.

If you have any questions about how your personal information is used, you can contact me at:

Email: nick@nickspinks.co.uk

Information I may collect

When you make an enquiry or undertake psychotherapy with me, I may collect information including your:

• name and contact details;
• date of birth and other relevant identifying information;
• emergency contact details;
• correspondence and appointment information;
• information provided during an initial consultation;
• brief clinical and session notes;
• information relevant to your psychological and physical health, relationships, personal history and current circumstances;
• payment and invoicing information.

Psychotherapy may involve information about mental or physical health, sexuality and other aspects of your personal life. Some of this is classed as special category personal data under UK data protection law and receives additional protection.

I aim to collect only information that is relevant and necessary for providing psychotherapy safely and professionally.

How I use your information

I may use your personal information to:

• respond to enquiries;
• arrange and manage appointments;
• assess whether I can appropriately offer psychotherapy;
• provide psychotherapy and maintain appropriate clinical records;
• communicate with you about your therapy;
• manage payments and accounts;
• meet my professional, ethical, safeguarding, insurance and legal responsibilities;
• establish, exercise or defend legal claims where necessary.

Lawful basis for processing

I process personal information only where there is a lawful basis for doing so under UK data protection law.

For information necessary to arrange and provide psychotherapy, this will ordinarily include processing necessary for the performance of a contract with you or to take steps at your request before entering into a contract.

In some circumstances, information may also be processed because I have a legitimate interest in operating a safe and professionally accountable psychotherapy practice or because I am required to comply with a legal obligation.

Psychotherapy records are likely to contain special category information, including information concerning health and, where relevant, sexual orientation. Where such information is necessary for the provision of psychotherapy, it is processed in accordance with the additional protections applying to health and social care information under UK data protection law.

The ICO confirms that Article 9(2)(h) can apply to processing necessary for the provision of health care or treatment where the information is processed by, or under the responsibility of, a professional subject to an obligation of professional secrecy.

Consent to psychotherapy and the therapeutic contract are separate from the legal bases on which personal information is processed.

Clinical records and security

I keep brief and appropriate records of my clinical work.

Electronic records are stored on password-protected devices and systems. Where paper records are necessary, they are stored securely in a locked filing cabinet.

I take reasonable steps to protect personal information from unauthorised access, loss, disclosure or misuse and aim to keep identifying information separate from clinical records where practicable.

Records are limited to information that is relevant to the provision of psychotherapy and my professional responsibilities.

How long I keep your information

Clinical records relating to adult psychotherapy are normally retained for seven years following the end of our work together. This reflects professional and insurance requirements. After the retention period, records will be securely destroyed unless there is a legal, regulatory, safeguarding or other compelling reason for them to be retained for longer.

Other information, such as enquiries from people who do not subsequently begin psychotherapy, will normally be retained for up to six months and will then be securely deleted, unless there is a legitimate reason for retaining it for longer.

Confidentiality and sharing information

Information disclosed during psychotherapy is treated as confidential.

I may discuss aspects of my clinical work within professional clinical supervision. Where possible, information is anonymised or limited to what is necessary for the purpose of supervision.

There are circumstances in which I may need to share information without your consent. These may include where:

• I am required to do so by law or court order;
• there is a serious concern about risk of harm to you or another person;
• safeguarding concerns arise;
• disclosure is otherwise necessary to meet a legal or professional obligation.

Where appropriate and possible, I would normally seek to discuss such a disclosure with you beforehand.

I may also use professional or technical service providers where necessary for the operation of my practice. They are expected to handle personal information appropriately and securely.

Online psychotherapy and Microsoft Teams

Online psychotherapy sessions are provided using Microsoft Teams.

When using Microsoft Teams, some personal information is necessarily processed through Microsoft's systems in order to provide the video-conferencing service. Psychotherapy sessions are not recorded by me, and I ask that clients do not record sessions.

Email

Email may be used for enquiries and practical communication concerning appointments and psychotherapy.

Although reasonable precautions are taken to protect information, ordinary email cannot be guaranteed to be completely secure. I therefore encourage you not to send detailed or highly sensitive clinical information by email unless necessary.

Clinical will

I have arrangements in place to protect clients in the event that I become seriously ill, incapacitated or die.

In such circumstances, a nominated professional colleague may be given limited access to the information necessary to identify and contact current clients and to manage the safe closure or continuity of the practice. Access would be limited to what is necessary for that purpose and would remain subject to professional confidentiality.

Website enquiries

If you contact me through the website enquiry form, the information you provide will be used for the purpose of responding to your enquiry and considering whether I may be able to offer psychotherapy.

Please avoid including detailed or highly sensitive clinical information in the website form. A brief indication of what you are seeking is sufficient at this stage.

If an enquiry does not result in psychotherapy, personal information relating to the enquiry will normally be retained for up to six months and will then be securely deleted, unless there is a legitimate reason for retaining it for longer.

Website analytics and cookies

This website is created and hosted using IONOS MyWebsite Now.

IONOS MyWebsite Now uses SiteAnalytics for statistical evaluation and technical optimisation of the website. IONOS states that SiteAnalytics does not use cookies. Information collected includes the referring website, pages or files requested, browser and operating system, device type, time of access and an anonymised IP address. IONOS states that this information is used for statistical and technical purposes and is not passed to third parties.

If additional third-party services are added to this website in future, this privacy notice will be updated where necessary.

Your rights

Under UK data protection law, depending on the circumstances, you may have rights concerning your personal information, including the right to:

• be informed about how your information is used;
• request access to personal information held about you;
• request correction of inaccurate information;
• request deletion of information in certain circumstances;
• request restriction of processing in certain circumstances;
• object to certain types of processing;
• request transfer of information where the right to data portability applies.

Some rights are not absolute and may be restricted where there is a lawful reason to continue processing or retaining information.

If you would like to exercise any of these rights, please contact me using the details above.

Concerns about your information

If you have concerns about how I have handled your personal information, I would encourage you to contact me in the first instance so that I can try to resolve them.

You also have the right to raise a concern with the Information Commissioner's Office (ICO), the UK's independent authority for data protection.

Changes to this Privacy Notice

This Privacy Notice may be updated from time to time to reflect changes in my practice, the services I use or applicable legal and professional requirements. The date at the top of this notice indicates when it was last updated.