Privacy Policy

Overview

Positive Mind Clinic takes the security of your personal information very seriously. For the purposes of UK data-protection law, Dominika Chalder, trading as Positive Mind Clinic, is the data controller responsible for your personal information. Positive Mind Clinic is registered with the Information Commissioner’s Office under registration number ZA850418.

To make sure your personal information is protected, I have a series of technical and administrative measures in place. I will treat your personal information in a way that is compliant with the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, and the Data (Use and Access) Act 2025 insofar as it amends those laws.

I rely on different lawful bases depending on why information is being processed. These may include:

contract, including taking steps at your request before therapy begins and providing and administering the agreed therapeutic service;
legitimate interests, including maintaining proportionate clinical records, undertaking confidential professional supervision, managing the practice safely, responding to complaints and protecting my legal rights;
legal obligation, where processing is necessary to meet a requirement imposed by law;
vital interests, in exceptional circumstances where processing is necessary to protect somebody’s life;
consent, where this is the appropriate basis for a specific optional activity, such as certain information sharing or recording; and
recognised legitimate interests, where processing is necessary for a qualifying purpose specified in law, such as certain safeguarding, crime-prevention or public-authority disclosure situations.

Where I rely on legitimate interests, I consider whether the processing is necessary and balance those interests against your rights, reasonable expectations and the potential effect upon your privacy. Where recognised legitimate interests apply, I will identify the applicable statutory condition and consider whether the processing is necessary and proportionate. A request from another organisation does not automatically require me to disclose information.

Where special-category information is processed, I will also identify an applicable condition under Article 9 of the UK GDPR. Further information about the principal condition used in providing psychotherapy appears in Section 2.

This privacy policy outlines your rights, and my obligations to you, with regard to the recording and storage of your personal information. In this privacy policy, I will let you know what information I need to collect from you before we begin therapy, and what information I need to collect from you during therapy. I will also set out how I will look after your personal information, for how long I will store it, and who I will share it with. In addition, I will let you know what you are able to request from me with regard to this information.

I will update this privacy policy from time to time. When I do change the policy (in a significant way), I will post an update on the Positive Mind Clinic website.

This privacy policy covers:

What personal information I collect
Special-category and criminal-offence information
How your personal information is stored and protected
How I use your personal information
Sharing your personal information with others
Accuracy and retention of personal information
Your individual rights
Electronic communications and protecting your privacy
Social media and public online interactions

1. What personal information I collect

You may be asked to provide your personal information anytime you are in contact with me. I will collect your personal information in the following ways: via the contact form on my website: www.positivemindclinic.co.uk, over the telephone, in writing, and during our meetings (online or in person). You are not required to provide the personal information that I may request, but, if you chose not to do so, in many cases I will not be able to provide you with appropriate services or respond to any queries you may have.

2. Special-category and criminal-offence information

I will collect a variety of information about you in several different ways. For instance, when you visit www.positivemindclinic.co.uk or .com I will collect the following information about your visit: I.P. address, location, search engine, date, time, web pages visited, operating system, and device.

If you request a call-back via the web form, I will collect the following information: name, email, date, and time.

Personal, special-category and criminal-offence information

The information processed in connection with enquiries, assessments and therapy may include ordinary personal information, special-category information and, where relevant, criminal-offence information. I only collect information that is reasonably necessary to assess your needs, provide safe and effective therapy, administer the therapeutic service and meet my professional or legal responsibilities.

Ordinary personal information

Ordinary personal information may include:

your name, date of birth, address and contact details;
your occupation and availability for appointments;
your family circumstances, relationships and support network;
your goals for therapy and relevant personal history;
appointment, payment and correspondence records;
your GP and emergency-contact details, where appropriate.

Some of this information may feel private or sensitive in the everyday sense, even though it is not legally classified as special-category information. I will nevertheless treat all personal information disclosed during therapy with care and confidentiality.

Special-category information

Because of the nature of psychotherapy, I am likely to process information which is legally classified as special-category data and therefore receives additional protection under data-protection law. This may include information concerning:

your physical or mental health;
diagnoses, symptoms, medication and previous treatment;
alcohol use or the use of prescribed or non-prescribed drugs;
racial or ethnic origin;
religious or philosophical beliefs;
political opinions;
trade-union membership;
sex life or sexual orientation;
genetic information or biometric information used for identification, if this is ever relevant.

I will only collect and record special-category information where it is relevant and reasonably necessary for assessing your needs, providing therapy, maintaining appropriate clinical records, managing risk or safeguarding, or meeting my professional and legal responsibilities.

Processing special-category information requires both a lawful basis under Article 6 of the UK GDPR and an additional condition under Article 9. For the provision of psychotherapy, I principally rely on Article 9(2)(h), where processing is necessary for the provision of health or social care or treatment and is undertaken subject to a professional duty of confidentiality, together with condition 2 of Schedule 1, Part 1 of the Data Protection Act 2018.

Where appropriate, a different condition may apply to a particular use of your information – for example, where processing is necessary to establish, exercise or defend a legal claim, protect someone’s vital interests or fulfil a safeguarding responsibility provided for by law.

Criminal-offence information

Information concerning criminal allegations, investigations, proceedings or convictions is not special-category information under Article 9. It is a separate category of information subject to additional protection under Article 10 of the UK GDPR and the Data Protection Act 2018.

I do not routinely require a complete history of previous convictions. However, you may disclose criminal-offence information during an assessment or therapy, or I may need to ask about it where it is directly relevant to:

your therapeutic needs or current circumstances;
assessing or managing a serious risk of harm;
safeguarding a child or an adult at risk;
providing safe and appropriate therapy;
complying with a specific legal obligation; or
establishing, exercising or defending a legal claim.

I will only record criminal-offence information when it is relevant and necessary. Any processing or disclosure will take place only where I have an appropriate lawful basis and a condition under the Data Protection Act 2018. Disclosure of criminal activity is not automatic merely because it has been discussed in therapy.

Information collected during assessment and therapy

During the complimentary initial assessment, I may ask for information including your:

name, contact details, date of birth and address;
availability and relevant personal circumstances;
reasons for seeking therapy;
current symptoms, difficulties and goals;
physical and mental health;
medication and current healthcare;
alcohol and other substance use;
appetite, sleep and relevant support arrangements.

The purpose of the assessment is to understand what support you are seeking, identify any relevant risks or contraindications, explain my therapeutic approach and decide whether I am appropriately qualified and able to work with you. You will also have an opportunity to ask questions before deciding whether to proceed.

If we agree to work together, I may collect further information relevant to your therapy, including:

your GP and emergency-contact details;
previous therapy or mental-health treatment;
relevant diagnoses, medication or healthcare involvement;
your family circumstances and support network;
relevant risk or safeguarding information;
other information that becomes relevant during therapy.

You do not have to disclose information that is not relevant to our work. However, withholding significant information about your health, medication, substance use, risk or current treatment may affect my ability to assess whether therapy can be provided safely.

Information from other professionals

Where it is helpful to communicate with your GP, psychiatrist, psychologist or another professional involved in your care, I will normally discuss this with you and obtain your explicit consent before making contact. In an emergency, where there is a serious safeguarding concern, or where another lawful justification applies, it may be necessary to share relevant information without prior consent. Wherever it is safe and reasonably possible, I will discuss this with you first. Any information shared will be limited to what is relevant and necessary for the purpose.

3. How your personal information is stored and protected

I store personal information in electronic and paper formats. I use appropriate technical and organisational measures to protect it against unauthorised access, accidental loss, alteration or disclosure.

Electronic information is stored on password-protected devices and, where available, protected using additional security measures such as biometric access, encryption and multi-factor authentication. Access is restricted to me, except where limited access is necessary under my professional-will arrangements or where an authorised service provider processes information on my behalf.

Paper records are stored securely in locked storage. Where practicable, identifying information, such as names and contact details, is stored separately from clinical notes, and clinical records are identified using a client reference rather than the client’s full name.

I do not share my passwords or devices with unauthorised individuals.

Access is restricted to me, except where an authorised service provider processes information on my behalf or where the executor of my professional will receives limited access in the circumstances described in Section 5.

Recording of sessions

I do not ordinarily record telephone, online or in-person therapy sessions. Sessions must not be audio-recorded, video-recorded, photographed, transcribed or processed using an automated or AI-enabled note-taking service without prior explicit agreement.

If recording is agreed for a specific therapeutic purpose, we will agree beforehand why it is needed, who will control and access it, how it will be stored and when it will be deleted.

Website contact form

If you contact me through the website contact form, the information you submit is sent to me by email. The website is configured not to retain the content of contact-form enquiries. Your information will then be handled in accordance with this Privacy Notice.

4. How I use your personal information

I only use your personal information for specified purposes connected with assessing your needs, providing and administering therapy, maintaining safe and ethical practice, and meeting my professional and legal responsibilities.

I may use your information to:

respond to your enquiry and assess whether I am appropriately qualified and able to support you;
understand your circumstances, therapeutic needs and goals;
plan, provide and review therapy that is responsive to your individual needs;
make informed clinical decisions and identify any relevant risks, safeguarding concerns or contraindications;
communicate with you about appointments, payments and other practical arrangements;
maintain appropriate clinical and administrative records;
discuss my clinical work within confidential professional supervision;
communicate with another healthcare professional or service where this has been agreed with you or where another lawful justification applies;
respond appropriately to emergencies, serious risks of harm or safeguarding concerns;
manage complaints, professional inquiries, insurance matters or legal claims;
maintain financial and tax records; and
meet any other applicable legal, regulatory, insurance or professional requirements.

I will not use your personal information for an unrelated purpose without first considering whether that use is compatible with the original purpose and whether a further lawful basis is required. I do not sell client information or use information disclosed during therapy for marketing.

Clinical records and data minimisation

I aim to keep clinical records concise, relevant and proportionate. I do not keep a verbatim account of therapy sessions or record everything you tell me. My records may include brief session notes, relevant assessment information, therapeutic plans, significant clinical decisions and information necessary for safe and accountable practice.

Where practicable, clinical notes are pseudonymised and identified using a client reference rather than your full name. Information that links the reference to your identity is stored separately and securely. Pseudonymised information remains personal information under data-protection law and receives the same legal protection.

I may need to maintain a more detailed written record where information relates to:

significant risk of harm to you or another person;
safeguarding a child or an adult at risk;
assessment of suicidal thoughts or self-harm;
domestic abuse, violence or other serious safety concerns;
significant clinical decisions, referrals or communications with other professionals;
consent to, or concerns about, a particular intervention;
complaints, professional investigations or insurance matters; or
the establishment, exercise or defence of a legal claim.

Maintaining such a record supports continuity of care, safe decision-making and professional accountability. It does not mean that information will automatically be disclosed to another person or organisation. Any disclosure will be considered separately in accordance with the confidentiality and information-sharing provisions of this Privacy Notice.

5. Sharing your personal information with others

I treat the information you share with me as confidential. I do not sell your personal information, provide it to third parties for their marketing purposes or disclose it unnecessarily.

There are limited circumstances in which information may be shared with another person or organisation. These include where:

you have asked me, or explicitly agreed, to share information;
confidential professional supervision is necessary;
another service provider processes limited information on my behalf;
disclosure is necessary to respond to a serious risk or safeguarding concern;
disclosure is required by law or a legally enforceable order;
disclosure is necessary to respond to a complaint, professional investigation, insurance matter or legal claim; or
another lawful and proportionate justification applies.

Whenever information is shared, I will consider its purpose carefully and disclose only what is relevant and reasonably necessary.

Insurance companies

If the cost of your therapy is being funded by an insurance company or another third-party funder, that organisation may require information to authorise or continue funding. This may include confirmation of attendance, relevant assessment information, treatment plans or progress reports.

I will explain, as far as reasonably possible, what information the insurer has requested and what may need to be disclosed. I will share only the minimum information reasonably necessary for the relevant purpose.

You should be aware that the insurer may make its own decisions about how it uses and retains information it receives, in accordance with its privacy notice and your agreement with it.

GPs and other healthcare professionals

It is not ordinarily necessary for me to contact your GP or another healthcare professional simply because you are receiving therapy. There may, however, be circumstances in which communication with your GP, psychiatrist, psychologist, consultant, dietitian, nutritionist, therapist or another professional involved in your care would support safe and coordinated treatment.

This might arise where:

clarification about medication, diagnosis or treatment is needed;
another treatment could interact with the therapy I provide;
specialist assessment or support may be appropriate;
your GP is required to make a referral to another service; or
coordinated care would otherwise be beneficial.

For routine communication, I will normally discuss the proposed contact with you, explain what information I consider relevant and obtain your explicit consent before sharing it.

Where appropriate, you may be given an opportunity to comment on the factual accuracy of a letter or report. However, I remain responsible for its clinical content and professional opinions. I will normally provide you with a copy unless there is a lawful, clinical or safeguarding reason not to do so.

In an emergency, where there is a serious safeguarding concern or where another lawful justification applies, it may be necessary to share relevant information without obtaining your prior consent. Wherever it is safe and reasonably possible, I will discuss this with you first.

Referrals to other services

If I believe that another professional or service may be better placed to meet some or all of your needs, I will normally discuss this with you before making a referral. I will usually obtain your explicit consent before providing identifiable information to the service. You may also choose to contact another provider yourself without asking me to disclose information.

Professional supervision

As a UKCP-registered psychotherapist, I undertake regular professional supervision. Supervision supports safe, ethical and accountable practice and is a standard part of providing psychotherapy.

Relevant aspects of my clinical work may be discussed with my supervisor. I ordinarily avoid disclosing names or other directly identifying details, and use only the information necessary for effective supervision. My supervisor is an appropriately qualified professional and is bound by duties of confidentiality. In exceptional circumstances – for example, when managing a serious risk, safeguarding concern, complaint or legal matter – it may be necessary to disclose identifying information within supervision or consultation. This will be limited to what is relevant and necessary.

Professional will

If I die, become seriously ill or am otherwise unexpectedly unable to practise, the executor of my professional will may receive limited access to the information necessary to identify and contact current clients, protect their welfare and arrange appropriate continuity or ending of therapy. The executor is a suitably qualified professional who is required to maintain confidentiality. This arrangement does not permit unrestricted access to clients’ clinical records.

Service providers

Some external providers may process limited personal information on my behalf in providing services such as:

email and electronic communications;
video consultations;
website hosting and contact forms;
secure electronic storage;
appointment or practice administration;
payment and banking services; and
accounting, technical support or data security.

These providers do not have permission to use your information for their own unrelated purposes. Where applicable, I take reasonable steps to use providers that offer appropriate contractual, technical and organisational safeguards.

Complaints, professional investigations and legal claims

Relevant information may need to be shared with my professional body, professional indemnity insurer, legal adviser or another appropriately authorised person if:

you make a complaint about my practice;
a professional or regulatory investigation takes place;
an insurance matter arises; or
information is necessary for the establishment, exercise or defence of a legal claim.

Only information reasonably necessary for addressing the particular matter will be disclosed. Those receiving it will have their own legal or professional duties concerning confidentiality and data protection.

Safeguarding and serious risk of harm

Confidentiality is not absolute. I may disclose relevant information without your consent where I have reasonable grounds to believe that:

a child may be experiencing, or be at risk of, abuse or serious neglect;
an adult at risk may be experiencing, or be at risk of, abuse, neglect or exploitation;
there is a serious and imminent risk of harm to you or another person; or
urgent intervention is otherwise necessary to protect someone’s life or safety.

A disclosure is not automatic solely because suicidal thoughts, self-harm, domestic abuse, substance use, criminal behaviour or another serious issue has been discussed. I will assess the circumstances, including the nature, seriousness and immediacy of the risk.

Where time and circumstances allow, I may consult my clinical supervisor, insurer, safeguarding adviser or legal adviser before deciding what action is appropriate. Wherever it is safe and reasonably possible, I will discuss the proposed disclosure with you first.

Legal requirements and public-authority requests

I may be required to disclose information where there is a valid court order, statutory reporting duty or another legally enforceable requirement. I may also receive a request for information from the police, a safeguarding authority or another organisation performing an official public function. Such a request does not automatically entitle that organisation to receive your therapy records and does not automatically require me to disclose them.

Where disclosure is not legally compulsory, I will consider whether it has a valid lawful basis and whether it is necessary and proportionate. I will verify the request where appropriate and disclose no more information than is reasonably necessary.

How I make decisions about disclosure

When considering whether information should be disclosed without your consent, I will take account of:

my duty of confidentiality to you;
the seriousness and immediacy of any risk;
the rights and safety of you and other people;
my safeguarding, legal and professional responsibilities;
whether the purpose could be achieved in a less intrusive way; and
whether the proposed information is relevant and proportionate.

Wherever circumstances permit, I will seek appropriate professional consultation and keep a record of the information considered, the decision made and the reasons for it.

6. Accuracy and retention of personal information

Keeping your information accurate

I take reasonable steps to ensure that the personal information I hold about you is accurate and, where necessary, kept up to date. Please let me know if your contact details, GP, emergency contact, medication or other relevant information changes during our work together.

You may ask me to correct personal information that you believe is inaccurate or incomplete. Where the information forms part of a clinical record, I may preserve the original entry where this is necessary to maintain an accurate professional record, while adding a correction, clarification or note that you dispute the information.

How long I retain information

I retain personal information only for as long as it is reasonably necessary for the purpose for which it was collected, including the provision of therapy, professional accountability, insurance, taxation, safeguarding and the establishment, exercise or defence of legal claims.

My ordinary retention periods are as follows:

Clinical and assessment records: ordinarily retained for seven years from the date of our last therapeutic contact or the ending of therapy, in accordance with my professional-indemnity insurer’s requirements.
Initial enquiries that do not proceed to an assessment or therapy: ordinarily retained for up to 12 months after the last contact, unless there is a documented reason to retain them longer.
Assessments that do not lead to ongoing therapy: ordinarily retained for seven years where a substantive clinical assessment, risk assessment, recommendation or professional decision has been made. Brief preliminary enquiries that do not amount to a clinical assessment are retained for the shorter enquiry period above.
Emails, messages and correspondence: relevant clinical, safeguarding, consent, complaint or contractual correspondence may be incorporated into the client record and retained for the same period as that record. Routine administrative messages will be deleted when they are no longer reasonably necessary.
Invoices, payment information and financial records: retained for the period required by applicable tax, accounting and legal requirements.
Complaints, safeguarding matters, insurance matters and legal claims: retained for as long as reasonably necessary to manage the matter and comply with any applicable legal, insurance or professional requirements.

Clinical records may be retained beyond the ordinary seven-year period where this is necessary because of:

an ongoing or reasonably anticipated complaint, professional investigation, insurance matter or legal claim;
a safeguarding matter or continuing serious risk concern;
a court order or other legal requirement;
advice from my insurer or legal adviser; or
another documented professional or legal reason.

Any decision to retain information beyond the ordinary period will be reviewed and documented. Information will not be retained indefinitely merely because it might conceivably become useful.

Secure destruction

At the end of the applicable retention period, paper records will be securely destroyed and electronic records will be securely and permanently deleted, subject to the operation of secure backup systems and any continuing legal or professional requirement. Where information remains temporarily within a protected backup, it will not ordinarily be used for any other purpose and will be removed or overwritten in accordance with the relevant backup cycle.

7. Your individual rights

Data-protection law gives you a number of rights concerning your personal information. The rights that apply will depend on the circumstances, including the type of information involved, why it is being processed and the lawful basis relied upon. These rights are not all absolute. In some circumstances, I may need or be permitted to continue processing or retaining information – for example, to comply with a legal obligation, maintain appropriate healthcare records, protect another person’s rights, address safeguarding concerns or establish, exercise or defend a legal claim.

You may exercise any of the rights described below verbally or in writing by contacting me at:

Email: domch@positivemindclinic.com

I may ask for information reasonably necessary to verify your identity, particularly before releasing confidential clinical information. I may also ask you to clarify the information or processing to which your request relates. I will respond without undue delay and ordinarily within one month. This period may be extended by up to a further two months where permitted by law – for example, if a request is particularly complex or you have made several requests. If an extension is required, I will explain this to you.

Requests will ordinarily be handled free of charge. A reasonable administrative fee may be charged, or a request may be refused, only where permitted by law – for example, where a request is manifestly unfounded or excessive. This is a high threshold, and any decision to charge a fee or refuse a request will be explained to you.

Your right of access

You have the right to ask whether I am processing your personal information and to request a copy of the information I hold about you, together with information about how it is being used. A request for access is sometimes called a subject access request. It does not have to be made in writing or use any particular wording. In responding to an access request, I am required to conduct reasonable and proportionate searches for your information. Information may be withheld or redacted where an applicable legal exemption applies, including where disclosure would adversely affect another person’s rights or reveal confidential information about somebody else. Where appropriate, I may provide an explanation or summary to help you understand clinical abbreviations or the context in which information was recorded.

Your right to rectification

You have the right to ask me to correct personal information that is inaccurate or to complete information that is incomplete. Clinical records may contain professional observations, formulations or opinions made at a particular time. If you disagree with such an entry, this does not necessarily mean that the original record is factually inaccurate or must be erased. Where appropriate, I may preserve the original entry to maintain the integrity of the clinical record while adding a correction, clarification or note recording your views. Where I prepare a report or letter about you for a third party, I will normally give you an opportunity to comment on its factual accuracy where it is appropriate to do so. I remain responsible for its clinical content and professional opinions, and there may be exceptional legal, clinical or safeguarding circumstances in which it cannot be shown to you before disclosure.

Your right to erasure

In certain circumstances, you have the right to ask me to erase your personal information. This may apply, for example, where:

the information is no longer necessary for the purpose for which it was collected;
the information has been processed unlawfully;
you withdraw consent where consent is the applicable lawful basis and no other lawful basis applies; or
you successfully object to particular processing.

The right to erasure is not absolute. I may need or be permitted to retain information where, for example, it is necessary:

to comply with a legal obligation;
for the provision or management of healthcare;
to meet relevant professional or insurance requirements;
in connection with safeguarding or serious risk;
to protect another person’s rights; or
to establish, exercise or defend a legal claim.

If information cannot lawfully be erased, I will explain the reason to you.

Your right to restrict processing

In certain circumstances, you may ask me to restrict how I use your personal information. This may apply, for example, while I verify the accuracy of information you have challenged or consider an objection you have made. Restriction usually means that the information will continue to be stored but will not otherwise be used, except where processing is permitted by law.

Your right to object

You may object to processing based on legitimate interests, including recognised legitimate interests, where your right to object applies. If you object, I will consider your particular circumstances and whether there are compelling legitimate grounds for continuing the processing or whether it is required for the establishment, exercise or defence of a legal claim. I do not use information disclosed during therapy for direct marketing. If personal information were ever processed for direct-marketing purposes, you would have an absolute right to object to that use.

Your right to data portability

In certain circumstances, you may ask to receive personal information that you provided to me in a structured, commonly used and machine-readable format. You may also ask for that information to be transmitted to another organisation where this is technically feasible.

This right generally applies only where:

the processing is based on your consent or a contract;
the processing is carried out by automated means; and
the information was provided by you.

It does not necessarily apply to all clinical notes, professional opinions, paper records or information obtained from other sources. The right to portability does not prevent you from asking for information under your separate right of access.

Your right to withdraw consent

Where I rely on your consent to process information for a particular purpose, you may withdraw that consent at any time by contacting me. Withdrawal will not affect the lawfulness of processing carried out before consent was withdrawn. It will also not affect processing that is necessary under another lawful basis, such as the performance of our therapy contract, compliance with a legal obligation, legitimate interests or the establishment, exercise or defence of legal claims. Withdrawing consent to optional information sharing may affect my ability to coordinate your care with another professional, but I will explain any likely consequences to you.

Automated decision-making

I do not use solely automated decision-making or profiling to make decisions about your eligibility for therapy, treatment or care that would produce legal or similarly significant effects upon you.

If I cannot comply with a request

If I cannot comply fully or partly with a request, I will explain the reason, unless the law prevents me from doing so. I will also tell you about your right to complain to the Information Commissioner’s Office and, where applicable, your right to seek a legal remedy.

Data-protection complaints

If you have concerns about how I have collected, used, stored, shared or otherwise processed your personal information, you may make a data-protection complaint by emailing domch@positivemindclinic.com with the subject line “Data Protection Complaint” or writing to the postal address provided at the beginning of this Privacy Notice.

You do not have to use a particular form. To help me investigate your complaint, please provide:

your name and contact details;
a description of your concern;
any relevant dates, correspondence or supporting information; and
the outcome you would like me to consider.

I may request information reasonably necessary to verify your identity or clarify the complaint.

I will acknowledge receipt of your complaint within 30 days. I will begin making appropriate enquiries without undue delay and will keep you informed if the investigation cannot be completed promptly. Once the investigation is complete, I will explain the outcome and any action taken without undue delay.

If you remain dissatisfied, you have the right to complain to the Information Commissioner’s Office. The ICO will ordinarily expect you to have raised your concern with me first so that I have an opportunity to address it.

Information Commissioner’s Office

Website: www.ico.org.uk/make-a-complaint

Telephone: 0303 123 1113

8. Electronic communications and protecting your privacy

I take appropriate technical and organisational measures to protect your personal information against unauthorised access, accidental loss, alteration or disclosure. However, no method of electronic communication or transmission over the internet can be guaranteed to be completely secure.

Email, text messages and other electronic communications may carry particular privacy risks. For example, messages may be accessed by someone who has access to your device, email account, telephone, shared address or notification screen. Information may also be exposed through loss or theft of a device, misdirected messages, insecure networks, malware or unauthorised access to an account.

I will take reasonable care to:

verify contact details where appropriate;
use the contact methods agreed with you;
limit sensitive information included in routine administrative communications;
use suitable security measures for confidential documents where appropriate; and
use video-consultation and other service providers that offer appropriate privacy and security safeguards.

You can help protect your privacy by:

providing contact details that are private and secure;
keeping your devices and accounts protected by passwords or other appropriate security measures;
checking who has access to your email, telephone, post and message notifications;
avoiding the use of shared accounts or unsecured public networks for sensitive communications;
checking the recipient’s address before sending confidential information; and
letting me know promptly if your contact details change or you believe a communication may have been accessed by someone else.

Please tell me if it is not safe or appropriate to leave voicemail messages, send text messages, use a particular email address or post information to your home address. We can agree the most suitable method for routine communication.

Email and messaging should ordinarily be used for appointment arrangements and other administrative matters rather than urgent clinical support. I cannot guarantee that electronic messages will be read immediately. If you require urgent help or believe that you or another person is in immediate danger, you should contact the appropriate emergency or crisis service rather than relying on an email or message to me.

If I become aware of a personal-data breach involving your information, I will assess it and take appropriate action in accordance with data-protection law. Where the breach is likely to result in a high risk to your rights and freedoms, I will inform you without undue delay unless an applicable exception applies.

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9. Social media and public online interactions

I use public professional accounts on platforms such as Facebook, Instagram and YouTube to share information about my practice and general mental-health or wellbeing content. Information shared through these accounts is general and is not a substitute for individual therapy, assessment, crisis support or medical advice.

Connections with clients

To preserve confidentiality, privacy and appropriate therapeutic boundaries, I do not send or accept personal friend or connection requests from current clients.

I also ordinarily do not send or accept personal connection requests from former clients. Therapeutic boundaries and confidentiality may remain relevant after therapy has ended, and an online connection could reveal or invite assumptions about our professional relationship.

You are free to view or follow the public professional accounts associated with my practice. However, I will not ordinarily follow clients or former clients back, view their personal profiles or interact with their personal content.

Following, liking or commenting on a public account may be visible to other people and could allow them to infer that you have an interest in my practice or services. Please consider your preferred level of privacy before interacting publicly. I cannot control how social-media platforms display or use information about your activity.

Messages and comments

Social-media platforms should not be used to arrange therapy, discuss clinical matters, disclose confidential information or request urgent support.

I do not provide therapy or individual clinical advice through direct messages, public comments or other social-media interactions. I may not see messages promptly and cannot guarantee the privacy or security of information sent through these platforms.

If you contact me through social media, I may provide a brief response directing you to an appropriate professional communication channel. I will not discuss our therapeutic relationship publicly or confirm whether you are, or have been, a client.

Where a social-media message contains clinically significant, safeguarding, complaint or risk information, it may be necessary to retain an appropriate record or take proportionate action rather than simply delete it. Other unsolicited social-media communications will be deleted when they are no longer required.

For appointments or administrative matters, please contact me at domch@positivemindclinic.com. Social media must not be used in an emergency. If you or another person is in immediate danger, contact the emergency services or an appropriate crisis service.

Incidental online contact

I do not routinely search for information about clients or former clients online. Exceptionally, I may consider doing so where there is a serious and immediate concern for somebody’s safety or another compelling professional or legal reason. Any such action will be limited, proportionate and appropriately documented.

If we encounter one another in an online group, public forum or other shared digital space, I will not acknowledge our therapeutic relationship unless you initiate this and it is appropriate to respond. Even if you acknowledge me publicly, I will avoid confirming confidential information about our work.

Testimonials and reviews

I will not ask current clients to provide testimonials or reviews. I also do not ordinarily solicit testimonials from former clients, because of the power imbalance within the therapeutic relationship and the potential implications for confidentiality, privacy and professional boundaries.

If you independently choose to leave a public review or comment, please be aware that this may reveal that you have used my services. I will not normally respond in a way that confirms you are or were a client. I cannot control how the platform uses, retains or displays information that you publish.

I will not publish identifiable clinical material, feedback or a testimonial supplied directly to me without a separate, specific and ethically appropriate process, including consideration of confidentiality, informed consent, therapeutic influence and your ability to withdraw permission where applicable.

My professional conduct is governed by the UKCP Code of Ethics and Professional Practice. You can read the code of ethics here:

https://www.psychotherapy.org.uk/about-ukcp/how-we-are-structured/ukcp-committees/ethics-group/code-of-ethics-updated/