YOUR INFORMATION
Privacy notice.
How I use and protect the personal information you share with Ingledow Therapy.
Who I am
I am Ben Ingledow, trading as Ingledow Therapy, and I am the data controller for the personal information I process in connection with my counselling and psychotherapy practice.
Email: bingledow.work@outlook.com
Correspondence address: Currock Community Centre, Lediard Avenue, Currock, Carlisle CA2 4BS
ICO registration reference: C2034830
What information I may collect
Depending on your contact with Ingledow Therapy, I may process:
- your name and contact details
- enquiry and appointment information
- information provided during assessment and therapy
- counselling/session notes
- information relating to risk or safeguarding
- emergency-contact details
- records of your Counselling Agreement and acceptance
- relevant emails and messages
- payment and invoice information
- information relating to complaints, insurance claims or data-protection concerns.
Counselling records may include special-category personal data, including information about physical or mental health and other sensitive information that you choose to discuss in therapy.
Why I use your information
I use personal information where necessary to:
- respond to enquiries and decide whether I can appropriately offer therapy
- provide counselling and psychotherapy
- arrange and administer appointments
- maintain appropriate clinical records
- manage risk and safeguarding concerns
- communicate with you about the service
- process payments and maintain accounting records
- obtain professional supervision
- meet professional, legal, insurance and regulatory responsibilities
- respond to complaints, claims or data-protection concerns.
Lawful basis
For most information required to arrange and provide counselling, I rely on Article 6(1)(b) UK GDPR — processing necessary to take steps at your request before entering into a contract or to perform our counselling contract.
Where processing is necessary to meet a legal requirement, such as certain financial and tax records, I may rely on Article 6(1)(c) — legal obligation.
For limited activities such as professional supervision, emergency-contact information, complaints and the protection of my legitimate professional interests, I may rely on Article 6(1)(f) — legitimate interests, where those interests are not overridden by your rights and interests.
Because counselling routinely involves health and other sensitive information, I generally rely on Article 9(2)(h) UK GDPR — provision or management of health or social care, together with the relevant condition under the Data Protection Act 2018, for clinical processing.
Where information is required for the establishment, exercise or defence of legal claims, Article 9(2)(f) may apply.
I do not generally rely on a blanket form of “GDPR consent” as the legal basis for providing counselling.
Where information is stored
I use both WriteUpp and Microsoft OneDrive for Business, within a Microsoft 365 Business Basic account, to store and manage clinical and practice records.
Access is restricted to me and protected using security measures including multi-factor authentication, device encryption, automatic screen locking and restricted account access.
My current administrative email address is bingledow.work@outlook.com.
Financial information may also be held by my bank or other payment/accounting providers where necessary.
Website and online enquiries
If you submit an initial enquiry through an online form on the Ingledow Therapy website, I use Tally, an online form provider based in Belgium, to receive and store the details you provide. This may include your name, email address, optional telephone number, session preference and a short message. The information is used to respond to your enquiry and make any arrangements you request. Tally acts as a data processor on my behalf.
I may receive email notifications about these submissions at my work email address. Information submitted in Tally and the related email correspondence is handled according to the retention periods in this notice. For an unsuccessful enquiry, my intended period is normally six months after the last contact. On the free Tally plan, deletion of submissions must be managed manually; the practice must implement and verify that process.
Please do not send detailed medical information, diagnoses or other sensitive personal history through the initial enquiry form. If more information is needed, I will discuss an appropriate way to provide it.
For more information about the provider, see Tally's privacy information.
Emergency contacts and information about other people
If you provide the name and contact details of an emergency contact, I will process that person's information for emergency and risk-management purposes.
Their information has been provided to me by you rather than directly by them. I will only use it where reasonably necessary and will normally delete the live emergency-contact details when therapy ends and they are no longer required for active care or risk management.
If an emergency contact becomes involved in a significant clinical, safeguarding, complaint or legal event, the relevant factual record may instead be retained as part of the appropriate record.
How long I keep information
Clinical records are currently intended to be retained for 7 years after therapy ends. This period is under review pending confirmation of any relevant requirement or recommendation from my professional indemnity insurer.
Unsuccessful enquiry information is normally deleted 6 months after the last contact.
Routine emails and messages are normally deleted 12 months after therapy ends or the last relevant contact. Clinically significant information may instead be transferred into the clinical record and retained with that record.
Appointment information is normally retained for up to 12 months after therapy ends, unless it forms part of the clinical record.
Financial and tax records are kept for the period required by HMRC.
Emergency-contact details are normally deleted after therapy ends once they are no longer required.
Where a complaint, safeguarding matter, insurance claim or legal issue remains unresolved, relevant information may be retained for longer where necessary and justified.
The seven-year clinical period is a practice retention decision rather than a universal statutory counselling rule and may be amended following insurer advice.
International processing
Some technology providers may process or store information outside the United Kingdom. Where this occurs, Ingledow Therapy will use providers and contractual safeguards intended to ensure that personal information receives the protections required by UK data-protection law.
Details of the relevant arrangements are maintained in Ingledow Therapy's internal data-protection records.
Your rights
Depending on the circumstances, you may have rights including:
- access to personal information held about you
- correction of inaccurate information
- deletion of information in certain circumstances
- restriction of processing in certain circumstances
- objection to certain processing
- data portability where applicable.
These rights are not absolute and may depend on the legal basis for processing and other legal or professional obligations.
You can contact me using the details above if you wish to exercise a data-protection right.
Data-protection concerns and complaints
If you are concerned about how I have handled your personal information, please contact me at bingledow.work@outlook.com. I will acknowledge a data-protection complaint within 30 days, investigate it appropriately and inform you of the outcome without undue delay.
You also have the right to complain to the Information Commissioner's Office (ICO).
Changes to this notice
I may update this Privacy Notice where my services, systems, legal obligations or data-processing arrangements change.
The current version will be provided or made available to clients where appropriate.
If you have questions about this notice or your information, contact bingledow.work@outlook.com.
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