Marketing 

If we send you marketing communications and you no longer wish to receive them, you can opt out anytime by contacting us or clicking on the ‘unsubscribe’ button on our marketing communications. Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business). 

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time. 

Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party links and marketing 

Our website might link to third-party websites, tools and apps. Clicking on these links may allow third parties to collect or share your data. We do not control said websites and are not responsible for said websites’ privacy policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table ‘Purposes for which we will use your personal data’ above.

• Service providers, acting as processors who provide IT and system administration services.

• Professional advisers, acting as processors or joint controllers, including healthcare professionals, lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

• If you are referred by your health insurance provider, then we may need to share details about your appointment schedule with your insurer for the purposes of billing and to provide treatment updates.

• As a HCPC-accredited clinician, we are obliged to consult with another mental health professional for supervision purposes. This is to ensure we reflect and improve on our clinical skills. When discussing clients in supervision we only refer to clients by their first name and identifiable information is minimised. Where you have provided explicit consent, audio and/or video recordings of therapy sessions may be shared with our clinical supervisor solely for this purpose. Recordings are transferred securely via encrypted email or password-protected cloud link, and access is restricted to the therapist and their supervisor only.

• Sometimes we may need to share details with your GP or a NHS mental health team.  We will always get your consent prior to doing this.  When the information concerns risk of harm to the client or another person then we may need to disclose information about you without your consent for your own safety or for the safety of someone else.  

• If you are referred to another psychologist or healthcare professional for specialist care or assessment, your relevant information may be shared with them to ensure continuity of care and appropriate treatment.

• HM Revenue & Customs, regulators and other authorities, acting as processors or joint controllers, based who require reporting of processing activities in certain circumstances.

• Debt collection agencies in the event that payment is not received for services rendered. This will be done to recover any outstanding debts, and the debt collectors will process your data solely for this purpose.

• We may need to share your personal data with courts, legal representatives, or other relevant authorities for medico-legal purposes. This includes situations where we are required to do so by law, or where it is necessary to protect your vital interests or the interests of another person. We ensure that this data sharing is conducted lawfully and with due regard for your privacy rights.

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We may transfer your data outside the United Kingdom/European Economic Area (EEA), but only when we can be sure it is protected.

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA (e.g. Zoom).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom. 

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. By law we have to keep medical information about patients for 7 years after treatment has finished. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

Therapy Session Recordings

Where you have consented to the recording of a therapy session for clinical supervision purposes, the recording will be securely deleted within 7 days of our supervisor viewing the recording. Recordings are not retained beyond that period and are not used for any purpose other than clinical supervision.

Discovery Calls

Where we conduct a discovery call or initial consultation with a prospective client, the following retention periods apply:

• Where no clinical judgement was formed: If the call was exploratory in nature and we collected only basic contact details (such as your name, email address and telephone number), and you do not proceed as a client, we will securely delete that information within one month of the call. This aligns with the storage limitation principle under UK GDPR.

• Where a clinical judgement or risk-related decision was made: If, during the discovery call, we formed any clinical assessment of suitability, noted a safeguarding concern, or made any risk-related decision, we will retain a brief record of that call even if you do not proceed as a client. This is consistent with good clinical governance and is supported by UK GDPR's provisions for processing in the context of health-related data and legal claims. In such cases, retention periods will follow applicable professional body guidance - 7 years for adults from the date of the call, and until the individual's 25th birthday where the prospective client was a child at the time of the call. 

For information that does not fall under the definition of basic, to determine the appropriate retention time, we look at what kind of data it is, how sensitive it is, the risks if it's misused, why we need it, and if there are other ways to achieve the same goals. We also consider applicable legal, regulatory, tax, accounting and other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  You have the right to:

Request access to your personal data (commonly known as a "Subject Access Request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

We’ll respond within one calendar month, but if we need to verify your identity first, we may pause the clock while we do so. This helps protect your data and ensures we’re sharing it with the right person.  If your request is complex or repetitive, we may apply proportionality rules under the Data (Use and Access) Act 2025, which allow us to limit the scope or extend the response time. We’ll always explain why and keep you informed.  To make a request, just email us at hello@drclaudiahallett.co.uk with the subject line “DSAR Request”. You don’t need to use legal language - just let us know what you’d like to see or understand.  If you’re unhappy with how we handle your request, you can raise a concern with the Information Commissioner’s Office (ICO) at www.ico.org.uk

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 

• If you want us to establish the data's accuracy.

• Where our use of the data is unlawful but you do not want us to erase it.

• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. 

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unjustified, repetitive or excessive. We also reserve the right to not comply in this scenario. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

10. Changes to the Privacy Policy

Dr Claudia Hallett reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the website and you are deemed to have accepted the terms of the Privacy Policy on your first use of the Website following the alterations. Please keep us updated if your personal data changes. If you have any questions or need to exercise your rights, just get in touch.

Thanks for reading our privacy policy. If you have any questions, please don't hesitate to contact us.