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 Privacy Policy

Welcome

‍Thank you for visiting my website. I understand that privacy is especially important when seeking psychological support, and I take protecting your personal information very seriously.

‍This privacy policy explains how I collect, use, store, and protect your information when you use my website or engage in therapy with me. My aim is to be open, transparent, and respectful, while providing a safe and confidential space in line with my professional and legal responsibilities.

‍Please read this policy alongside any other privacy information I may provide.

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Who is responsible for your data?

‍I am the data controller for any personal information you share with me.

Name: Motchila Innocente
Email: [INSERT EMAIL]
Telephone: [INSERT NUMBER]

‍If you have any questions about how your information is handled, please contact me using the details above.

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If you have a concern

‍I am committed to handling your personal data with care, transparency, and respect.

‍If you have any questions or concerns about how your information is used, please contact me in the first instance and I will do my best to resolve the issue promptly and fairly.

‍Under the Data (Use and Access) Act 2025, you also have the right to raise a concern about how your personal data is handled.

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How to raise a concern:

  • ‍ 1. Email me at [INSERT EMAIL] with a brief description of your concern

  • 2. I will acknowledge your message and aim to respond without undue delay, usually within 10 working days.

  • 3. If you remain dissatisfied, you can contact the Information Commissioner’s Office (ICO) at www.ico.org.uk.

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What information do I collect?

‍Personal data means information that can identify you. I may collect and use the following:

Personal and contact details

  • Such as name, title, date of birth, gender

  • Email address, telephone number, address

  • Contact details for your GP, other relevant health professionals involved in your care and your emergency contact person

Technical information

  • IP address, browser type and version, device and operating system information

  • Information about how you use my website

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Financial information

  • Payment and billing details

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Usage information

  • Information about how you use my website and services

Special category data

‍As a Clinical Psychologist, I collect sensitive information, including:

  • Medical and mental health history

  • Other relevant health and personal information needed to provide safe and effective psychological care

‍I will seek your explicit consent before processing this type of information.

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How do I collect your information?

‍ I collect information directly from you when you:

  • Enquire about or engage in therapy services

  • Complete assessment or onboarding forms

  • Share information during therapy sessions

  • Communicate with me by email, phone, or other means

  • Provide feedback

‍I may also collect limited information automatically through cookies and similar technologies when you visit my website. Please see my Cookie Policy for more details.

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What happens if you don’t provide required information?

‍In some situations, I am legally or professionally required to collect certain information, or I need it to provide therapy safely. If you choose not to provide this information, I may not be able to offer or continue services. I will explain this clearly if it applies.

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Why do I use your information?

‍I use your personal data to:

  • Register you as a client

  • Provide psychological assessment and therapy

  • Manage appointments, payments, and fees

  • Communicate with you about your care or changes to my services

  • Maintain and improve my website and services

  • Meet my legal, regulatory, and professional obligations

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Lawful bases for processing

‍I process your personal data using one or more of the following lawful bases:

  • Contract – to provide therapy services

  • Legal obligation – including tax, record-keeping, and safeguarding

  • Consent – particularly for health information

  • Recognised legitimate interests

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Recognised legitimate interests

‍Under theData (Use and Access) Act 2025, I may process personal data where this supports important professional responsibilities, while respecting your rights. This includes:

  • Safeguarding and risk management

  • Clinical supervision (as required by HCPC standards)

  • Preventing fraud or misuse of services

  • Responding to emergencies

  • Improving accessibility and inclusion

‍I always consider whether my interests are balanced against your rights and freedoms. You have the right to object to this type of processing at any time.

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Cookies

‍Cookies help my website function properly and improve your experience by remembering preferences.

‍You can manage or disable cookies in your browser settings. More information is available in my Cookie Policy

Third-party links

‍My website may include links to third-party websites or tools. I am not responsible for their privacy practices, and I encourage you to read their privacy policies if you visit them.

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Who do I share your information with?

‍I only share your information when it is necessary and lawful to do so, and always with appropriate safeguards.

‍This may include:

  • IT and website support providers

  • Professional advisers (such as accountants, insurers, or lawyers)

  • HM Revenue & Customs and regulatory bodies

  • Debt recovery services (if payments are overdue)

  • If you are referred by your health insurance provider I may need to share information with them for the purposes of billing or to provide treatment updates

To operate my practice and website I use the following third party service providers: Cliniko (practice management and client records), Squarespace (website hosting and contact forms) and Protonmail (secure email). Each act as a data processor on my behalf and are required to handle your data securely and in accordance with applicable law.

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Clinical, supervision, and safeguarding disclosures

‍As an HCPC registered Clinical Psychologist, I have professional obligations that may require information sharing:

  • I engage in regular clinical supervision with another Clinical Psychologist to reflect on and improve my clinical skills. When discussing cases, I minimise identifying information and refer to clients by initials only.

  • I may also seek specialist consultation or supervision where there are safeguarding concerns.

  • With your consent, I may sometimes share relevant information with other involved professionals such as your GP, psychiatrist, or social worker.

  • If you are referred to another healthcare professional, I may share relevant information to support continuity of care.

  • In exceptional circumstances, I may be obliged to share information about you (e.g. with your GP, social services or the police) without your consent. This would be in the case of concerns about risk of harm to you or to another person, including children, or where I am legally required to disclose information for the prevention, detection or prosecution of a crime.

  • I will aim to discuss such concerns and obligations with you before notifying relevant parties; however, this may not always be possible, and I will use clinical judgment to act in the best possible way to minimise possible harm.

  • I 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. I ensure that this data sharing is conducted lawfully and with due regard for your privacy rights.

‍All third parties are required to keep your information secure and confidential and may only use it for the agreed purpose.

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International transfers

‍Some service providers I use may be based outside the UK/EEA. When this happens, I ensure appropriate safeguards are in place, such as:

  • Transfers to countries recognised as providing adequate protection

  • Use of contracts approved by the UK Information Commissioner

‍You can contact me for further details.

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How I keep your information secure

‍I use appropriate technical and organisational measures to protect your personal data. Access is restricted to those who need it for legitimate purposes.

‍In the rare circumstance that there is a personal data breach, I will notify you and the relevant regulator where required by law.

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How long I keep your information

‍I keep your personal data only for as long as necessary.

  • Clinical records are kept securely for 7 years, in line with professional guidance

  • Basic client and financial records are kept for 6 years for tax purposes

When someone contacts me via the contact form or by email but does not go on to become a client, I will retain their contact details and message for up to 90 days from the date of contact, after which this information is securely delated. This includes submissions stored in my website contact form dashboard and any related email correspondence.

‍Retention decisions take into account legal, professional, and risk considerations.

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Your rights in relation to your information

‍You have the following rights regarding your personal data:

Access: You have the right to ask me what personal data I hold about you and to receive a copy of that data. This is called a Subject Access Request (SAR).‍ I will aim to respond within one calendar month, but if I need to verify your identity first, I may pause the clock while I do so. This helps protect your data and ensures I’m sharing it with the right person.  If your request is complex or repetitive, I may apply proportionality rules under the Data (Use and Access) Act 2025, which allows me to limit the scope or extend the response time. I  will always explain why and keep you informed.  To make a request, just email me with the subject line “DSAR Request”. You don’t need to use legal language - just let me know what you’d like to see or understand.  If you’re unhappy with how I handle your request, you can raise a concern with the Information Commissioner’s Office (ICO) at www.ico.org.uk

Correction: If the personal data I have about you is incomplete or incorrect, you can ask me to correct it.

Erasure:  You can ask me to delete your personal data. It's important to note, however, that there might be legal reasons that prevent me from fulfilling this request.

Objection: In certain situations, you have the right to object to the processing of your personal data.

Restriction of Processing: You can request that I restrict the processing of your personal data under specific circumstances.

Data Portability: You have the right to request the transfer of your personal data directly to you or to a third party of your choice.

Withdrawal of Consent: At any point where I rely on your consent to process your personal data, you have the right to withdraw this consent. Withdrawal of consent will not affect the legality of the processing done before the consent was withdrawn. Should you withdraw your consent, I might be unable to provide you with certain services.

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

‍I won’t charge any fees for you to request access to your personal data. However, a reasonable fee may be charged if your request is clearly unjustified, repetitive or excessive. I also reserve the right to not comply in this scenario. I try to respond to all legitimate requests within one month. Occasionally it could take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.

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Changes and contact

‍I review this privacy policy regularly and may update it from time to time.

‍If your personal details change, or if you have any questions or concerns, please get in touch. I am happy to help.

Innocente Psychology - Privacy Policy - March 2026