Dynamic Therapy Club Limited takes the protection and effective management of your data very seriously. In doing so, we will only obtain data that is necessary and has purpose to our legitimate business interests and for the benefit of the services we deliver.
As a counselling and therapies practice, we want everyone who uses our services to feel confident and comfortable about the way that we handle your personal information.
This Notice sets out what information we process & why, how we store it, what security is in place to protect your data and how you can access it or manage it.
The way that we process and protect your personal data is governed by the General Data Protection Regulation (GDPR). As of May 2018, GDPR replaced the existing data privacy laws to give you more rights and control over your data.
The role of Dynamic Therapy Club Limited
Our role is to comply with the regulations set out through GDPR. We do this by responsibly and effectively managing and processing the data that you share with us.
If there is anything within this notice that you would like clarified, then please contact us using the information below.
Adam Coombes is the data controller for Dynamic Therapy Club.
Whose information does this notice apply to?
This notice applies to information that we collect from:
Current, past & potential clients
Visitors & followers to our website or our social media channels.
What categories of information do we collect?
Due to the nature of the sessions held with clients, Dynamic Therapy Club collects “Personal” & sometimes “Sensitive” data.
Personal data defined
Personal data relates to any data that is capable of identifying an individual wholly or partly through automated means or manually as part of a filing system. Examples of personal data that we may process from you include:
Date of birth
Cookies and IP addresses on my website
Sensitive data defined
“Special category data” is sensitive data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.
Through the course of counselling practice or solution focused therapy, it may be necessary to collect some sensitive data that is relevant to the issues that you raise with us as part of a therapeutic relationship.
An example of some of the sensitive data that you may share and that we gather are:
Physical or psychological health conditions
Your ethnicity, religious or cultural beliefs
Sexual orientation or identity
Your Doctor’s details and relevant medication
Your political opinions
Details about your sex life.
Why we process this data
First and foremost, we process only data that is necessary. We process data to make our service as positive and beneficial to you as possible.
Dynamic Therapy Club stores and manages your personal information under Article 6 of the GDPR.
Consent – We may process your data with your given consent for a particular purpose.
Contract – When you begin your first session you agree to the terms in the counselling contract which is in place to protect the interests of both yourself and the counsellor.
Vital Interests – It may become apparent for us to process your data to protect someone’s life.
Legitimate interests – As a professional therapy service, we have a legitimate business interest to hold basic information about our clients so that we can manage bookings, arrange invoicing etc.
As professionals, to carry out an effective service, the counsellors may keep notes of themes bought up in sessions as well as the date and time of the session. These notes remain in the possession of the counsellor that you are working with and are not to be made available to other counsellors or members of Dynamic Therapy Club.
These notes are anonymised and kept on separate secure systems to those that contain your personal information. These notes are kept to provide the contracted counselling services that you have agreed for your counsellor to carry out with you.
Counsellors are required to keep basic record of sessions in the interests of insurance and legal interest.
If during sessions you explore through creative interventions (e.g. drawings, thought records) then these items will remain as yours at the end of the session.
How we obtain your data & how it is stored
We obtain your data in a number of ways:
Personal details form - completed prior to your first appointment, this is used to manage you as a client whereby we will internally allocate you a client number. Your personal data on this includes: Name, Address, DOB, Telephone number, email, diagnosis, medication, registration with doctor, & NOK details.
Data privacy notice – As part of the personal details form. This gains your consent for processing your data. The data obtained on this form – your name with an E-signature.
NB: The data privacy notice and basic personal details form is combined and a client number is allocated to you. These two forms are now digitally stored in a secure encrypted location.
Enquiry through our website – This can be completed by yourself at anytime and the information is sent to a secure mailbox for processing and response. The data obtained from this is: Your name, your email address & your telephone number. You can select the type of enquiry you are making and we will receive any information you wish to share in the message box. We would request that you do not disclose any other personal or sensitive information about yourself in the message field, only that you seek a service or add your query. This information is stored through our website Content management system.
Cookies and tracking - Cookies are small pieces of data stored on a site visitor's browser. They are typically used to keep track of the settings users have selected and actions they have taken on a site. When visiting www.dynamictherapy.club, you will be made aware of cookies being active and have an opportunity to consent to these or not.
We may use traffic log cookies to identify which pages are being used. This helps analyse data via Google Analytics about web page traffic and improve the website in order to tailor it to customer needs.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
Google Analytics - Each time you visit a website Google analytics automatically tracks information such as (but not limited to) your geographical location, IP address, browser type, browser version, operating system, referral source, page views, length of visit, the times and dates you visit the site, navigation paths, whether you are a new visitor or a returning visitor.
When you visit the information collected by Google analytics may be used by us to customise the website according to your interests and help improve products and services.
Social media – Dynamic Therapy has social media accounts with Facebook, Instagram, Twitter, Youtube and LinkedIn. This gives people an opportunity to like, follow and interact with us. In doing so, Dynamic Therapy Club can have limited access to the details of user’s social media accounts – although we do not exercise this! We do not export any user details from the platforms and direct users to read the relevant privacy policies for these platforms for further information on protecting your data.
Payment - For the purposes of appropriate & lawful accounting, if you are paying by way of transfer, card, or Payal then your details will be recorded by the relevant banking organisation. For the sake of transparency and to provide you with further avenues to explore if required: If you pay by card, then this is processed through Izettle & paid into the company account with Tide Banking. Through Tide, each transaction is stored and each session has an invoice generated which is attached to the transaction. The invoice will contain your name and session date/Time, as well as payment method details.
Self-disclosure in sessions – During your therapy sessions you may share information with us that would be classed as sensitive (see “sensitive data defined”). Your counsellor may take basic notes pertaining to themes discussed, however, notes will be anonymised and only your internal client reference number will attribute these notes to you. Counsellors are responsible for making and storing their own session notes and these will be stored securely on a separate locked system different to that of your personal information. These notes will not be made available to anyone at Dynamic Therapy Club. Note taking processes are necessary in the exercise of insurance & legal defence and to secure potential evidence in the event of a criminal prosecution, civil litigation, insurance claim or complaint to a regulatory body. For all avoidance of doubt – your client records do not contain any personal information and are identifiable only through client number.
Your rights and your personal data
Where we can, we will only collect and use personal information if we need to deliver a service or meet a requirement. Under the General Data Protection Regulation (GDPR), European based individuals have been given a set of “Individual Rights:”
Right to be informed – you will be told about the collection and use of your data for the purposes of transparency.
Right to access – to request data held about you via a ‘Subject Access Request’.
Right to rectification – if data held about you is incorrect, you have the right to get it changed.
Right to erasure – your data can be destroyed at your request if certain criteria are met.
Right to restrict processing – your data can be stored, and not processed in certain circumstances.
Right to data portability – allowing you to transfer your data from Dynamic Therapy Club to another service
Right to object – you can refuse for your data to be processed in certain circumstances.
Rights in relation to automated decision making and profiling – organisations can only automatically process some data if certain criteria is met.
For more information on your rights under the GDPR visit: www.ico.org.uk.
All sessions are conducted in confidence with date, time session number and client number recorded in brief notes.
If in the rare instance that there is a real risk to the safety of you or another based on what you have disclosed, then confidentiality will not be maintained. This is to safeguard your best interests and to maintain the counsellor’s professional integrity. This can include matters in safeguarding vulnerable adults or children, offences involving people under the age of 18 or cases of terrorism, fraud, drug trafficking or money laundering.
Where we are able, we will seek your permission to refer this matter to an appropriate authority or other support service. For reasons dictated by law governance, there may be occasions that we are forbidden from notifying you of a disclosure to a third party.
Your data will be stored for 5 years following the completion of therapy to which point if no requests have been grated, then it will be destroyed.
With your permission
We will seek your permission to share your data in the following instances:
To contact you via your preferred method and will only leave a message with your consent.
Share information outside of the above exceptions.
Publish any marketing material such as case studies or testimonials including those using a pseudonym.
Your confidence in security
Website – Dynamictherapy.club uses a secure server through Hyper Text Transfer Protocol Secure (HTTPS) –and this protection is validated by an Secure Sockets Layer (SSL) certificate. The website is designed on an ISO certified platform and has encrypted databases to store information that you may submit through.
Client notes and details are stored on two separate digitally encrypted storage systems.
Counsellors working with clients are only permitted to use the internal client number within their notes. All notes are stored away in locked or digitally encrypted locations.
Email systems are hosted through ISO & NIST certified and accredited platforms.
You may request details of personal information which we hold about you under the General Data Protection Regulation 2018 (GDPR). If you would like a copy of any stored personal information, please email firstname.lastname@example.org .
Dynamic Therapy aims to keep all personal data up to date, if you believe that any information we are holding about you is incorrect or incomplete, please write to us as soon as possible, at the above email address and we will promptly correct any information found to be incorrect.
We will not sell, distribute or lease your personal information to third parties unless we have your permission or is required by law to do so.
If you want any of your information transferred to another agency, we require this request in writing with a rationale to our email address.
Amendments & Updates
We hope by now that you have learned:
Who this policy relates to and whose details we process
What data we process.
How we process, manage, store, and protect your data
Why we collect your data
Your rights with your data when engaging with Dynamic Therapy Club.