Introduction

This privacy notice provides you with details of how Carly Ann Coaching Ltd collects and processes your personal data when you use our services and when you use our website.

Carly Ann Coaching Ltd is the data controller responsible for your personal data. In this privacy notice, “we”, “us” and “our” refer to Carly Ann Coaching Ltd.

We are committed to protecting your privacy and ensuring that your personal information is handled securely and in accordance with applicable UK data-protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Contact details

Our details are:

Carly Ann Coaching Ltd
Carly Turner
Email: carly@carly-ann.co.uk

It is important that the information we hold about you is accurate and up to date. Please let us know if your personal information changes by contacting us at carly@carly-ann.co.uk.

What personal data do we collect and why do we process it?

Personal data means information that can identify you directly or indirectly. We may collect and process different categories of personal data depending on the services you use and your relationship with us.

Communication Data

This includes information contained in communications you send to us, including enquiries made by email, telephone, online forms, text message or other communication methods.

This may include your name, contact details and the content of your communication.

We process this information in order to:

  • respond to your enquiries;
  • communicate with you about appointments and services;
  • maintain appropriate business and professional records; and
  • establish, exercise or defend legal claims where necessary.

Our lawful basis for this processing may be our legitimate interests, the performance of a contract, taking steps at your request before entering into a contract, or another lawful basis applicable to the circumstances.

Client Data

If you become a client, we may collect information including:

  • your name;
  • date of birth or age;
  • address;
  • email address;
  • telephone number;
  • emergency contact information where appropriate;
  • appointment information;
  • information about your coaching or therapy needs;
  • treatment or coaching goals;
  • session notes;
  • progress and outcome information;
  • correspondence relating to your sessions;
  • payment and invoicing information; and
  • other information reasonably necessary to provide our services.

We process this information to provide and administer coaching and/or CBT services, maintain appropriate professional records, communicate with you and manage our contractual and professional responsibilities.

Our lawful basis for this processing may include performance of a contract, legitimate interests, legal obligation, and, where applicable, an appropriate condition for processing special category data.

Health and other special category data

As part of providing CBT and coaching services, it may be necessary for us to collect information relating to your physical or mental health.

Health information is classified as special category personal data under UK data-protection law and requires additional protection.

This information may include:

  • information about your mental health;
  • information about your physical health where relevant;
  • relevant medical history;
  • medication information;
  • information about previous or current treatment;
  • information about your presenting difficulties;
  • risk and safeguarding information; and
  • information discussed during therapy or coaching sessions.

We only process this information where we have an appropriate lawful basis and an applicable condition for processing special category data under the UK GDPR.

Depending on the circumstances, this may include processing necessary for the provision of healthcare or treatment or, where appropriate, explicit consent.

We only collect information that is relevant and necessary for providing safe and appropriate services.

Sessionly

We use Sessionly as part of the administration and management of our practice.

Sessionly may be used to collect, store and manage information relating to clients, including:

  • contact information;
  • appointment information;
  • assessment information;
  • session information;
  • clinical or coaching notes;
  • outcome measures;
  • documents and forms; and
  • other information required to administer your sessions.

Sessionly is a third-party service provider used by Carly Ann Coaching Ltd.

We take reasonable steps to ensure that information processed through third-party systems is handled securely and in accordance with applicable data-protection requirements.

The information held within Sessionly is treated as confidential and is only accessed and used for appropriate purposes connected with the provision and administration of our services.

Further information about how Sessionly processes personal data, including its own privacy arrangements, security measures and any international data transfers, can be found in Sessionly’s current privacy information.

Website and Technical Data

When you use our website, we may automatically collect certain technical information.

This may include:

  • IP address;
  • browser type;
  • device information;
  • operating system;
  • time zone;
  • pages visited;
  • length of visits;
  • how you navigate around the website; and
  • other technical information.

This information may be collected through cookies and similar technologies.

We use this information where necessary to:

  • operate and maintain our website;
  • protect the security of our website;
  • understand how visitors use our website;
  • improve our website and services; and
  • monitor website performance.

Where required, we will obtain your consent before using non-essential cookies or similar technologies.

Please see our Cookie Policy for further information.

Information you provide directly to us

We may collect personal data when you:

  • contact us by email;
  • telephone us;
  • complete an enquiry form;
  • book an appointment;
  • complete an assessment form;
  • provide information through Sessionly;
  • attend a coaching or therapy session;
  • communicate with us about your treatment or coaching; or
  • otherwise provide information to us.

Information from third parties

Where appropriate and lawful, we may receive information from third parties.

For example, information may be provided by:

  • your GP;
  • another healthcare professional;
  • another therapist or practitioner;
  • a referral organisation;
  • an insurer; or
  • another person or organisation involved in arranging your care.

Where information is obtained from another person or organisation, we will only process it where there is an appropriate lawful basis to do so.

Where appropriate, we will obtain your consent before requesting or sharing information with another professional.

How we use your personal information

We may use your information to:

  • provide CBT and/or coaching services;
  • assess your needs;
  • plan and review your treatment or coaching;
  • maintain appropriate professional records;
  • communicate with you;
  • arrange and manage appointments;
  • send appointment reminders;
  • administer payments and invoices;
  • monitor outcomes and progress;
  • respond to enquiries;
  • manage safeguarding concerns;
  • comply with legal and professional obligations;
  • manage complaints;
  • maintain appropriate insurance and professional records; and
  • establish, exercise or defend legal claims.

We will only use your personal information for the purposes for which it was collected or for another purpose that is compatible with the original purpose, unless we have a lawful basis to use it for another purpose.

Confidentiality

We understand the importance of confidentiality within coaching and therapy.

Information you share with us will normally be treated as confidential and will not be disclosed to other people without your knowledge and, where appropriate, your consent.

However, confidentiality has limits.

There may be circumstances where we need to disclose information without your consent, including where:

  • there is a serious risk of harm to you or another person;
  • there are significant safeguarding concerns;
  • disclosure is required by law;
  • disclosure is required by a court or other lawful authority;
  • disclosure is necessary to protect someone’s vital interests; or
  • disclosure is otherwise permitted or required by law.

Where it is safe and appropriate to do so, we will normally discuss any proposed disclosure with you.

Clinical supervision

Carly Turner may discuss aspects of professional work with an appropriately qualified clinical supervisor as part of maintaining safe and effective professional practice.

Where possible, information will be anonymised or pseudonymised so that you cannot reasonably be identified.

Where identifiable information needs to be shared, this will only occur where there is an appropriate lawful basis and where the information sharing is necessary and proportionate.

Sharing your personal data

We may share your personal data with trusted third parties where this is necessary and lawful.

These may include:

  • Sessionly and other IT service providers;
  • professional supervisors;
  • accountants and bookkeepers;
  • professional advisers;
  • insurers;
  • legal advisers;
  • payment providers;
  • website and technology providers;
  • relevant healthcare professionals; and
  • government or regulatory bodies where required by law.

We require organisations processing personal information on our behalf to respect the security and confidentiality of your information and to process it only for specified purposes.

We will not sell your personal information to third parties.

International transfers

Some technology providers may process or store personal information outside the United Kingdom.

Where your personal information is transferred outside the UK, we will ensure that the transfer is made in accordance with applicable UK data-protection legislation and that appropriate safeguards are in place where required.

This may include using an adequacy decision, appropriate contractual safeguards or another lawful transfer mechanism.

Data security

We take reasonable technical and organisational measures to protect your personal information from:

  • accidental loss;
  • unauthorised access;
  • misuse;
  • alteration;
  • disclosure; or
  • destruction.

Access to personal information is limited to people who have a legitimate need to access it.

Where third parties process information on our behalf, we take reasonable steps to ensure that appropriate confidentiality and security arrangements are in place.

We also have procedures for responding to suspected personal-data breaches.

Where a breach occurs that is required to be reported under data-protection law, we will notify the relevant regulator and/or affected individuals as required.

Data retention

We only retain personal information for as long as it is necessary for the purposes for which it was collected and in accordance with our legal, professional and insurance obligations.

Clinical and therapy records may need to be retained for a period after therapy has ended.

Our retention periods take account of:

  • the nature of the information;
  • the sensitivity of the information;
  • professional requirements;
  • legal requirements;
  • insurance requirements;
  • the potential risk associated with retaining or deleting the information; and
  • whether the information is still required for its original purpose.

Our current clinical record retention period is: [INSERT RETENTION PERIOD].

Financial and accounting records will be retained for the period required by applicable legal and tax requirements.

When information is no longer required, it will be securely deleted or destroyed.

Marketing communications

We may occasionally send information about our services, events or other relevant business communications where we have a lawful basis to do so.

Where consent is required for marketing communications, we will obtain your consent before sending them.

You can ask us to stop sending marketing communications at any time by contacting:

carly@carly-ann.co.uk

Opting out of marketing communications will not affect the provision of any coaching or therapy services.

Automated decision-making

We do not make decisions about clients using solely automated decision-making that produce legal or similarly significant effects.

We do not use automated profiling to make clinical or therapeutic decisions about clients.

Your data protection rights

Under UK data-protection legislation, you may have rights in relation to your personal information.

These may include:

  • The right to access – you can request a copy of personal information we hold about you.
  • The right to rectification – you can ask us to correct inaccurate or incomplete information.
  • The right to erasure – in certain circumstances, you can ask us to delete your personal information.
  • The right to restrict processing – in certain circumstances, you can ask us to restrict how we use your information.
  • The right to object – in certain circumstances, you can object to particular processing.
  • The right to data portability – where applicable, you can request certain information in a structured, commonly used and machine-readable format.
  • The right to withdraw consent – where we rely on consent as our lawful basis, you can withdraw your consent.

These rights are subject to certain legal conditions and exemptions. In particular, we may need to retain clinical, financial or other records where there is a legal, professional or insurance requirement to do so.

How to exercise your rights

If you wish to exercise any of your data-protection rights, please contact:

Carly Turner
Carly Ann Coaching Ltd
Email: carly@carly-ann.co.uk

We may need to request information to verify your identity before responding to a request. This is an important security measure designed to prevent personal information being disclosed to someone who is not entitled to receive it.

We will normally respond to a valid request within one month, in accordance with applicable data-protection legislation.

Complaints

If you have any concerns about how we collect or use your personal information, please contact us first so that we have an opportunity to address your concerns.

Carly Turner
Carly Ann Coaching Ltd
Email: carly@carly-ann.co.uk

You also have the right to complain to the Information Commissioner’s Office (ICO), which is the UK’s independent supervisory authority for data protection.

You can find information about making a complaint on the ICO’s website:

Information Commissioner’s Office

Third-party websites

Our website may contain links to third-party websites.

If you follow a link to another website, that website will have its own privacy policy and terms of use.

We are not responsible for the privacy practices or content of third-party websites.

We recommend that you read the privacy policy of any third-party website you visit.

Cookies

Our website may use cookies and similar technologies.

Cookies may be used to:

  • make the website function correctly;
  • remember preferences;
  • understand how visitors use the website; and
  • improve the website.

Where required, we will ask for your consent before placing non-essential cookies on your device.

Please see our separate Cookie Policy for further information.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in legislation, professional guidance, our services, technology or the way we process personal information.

The latest version will be published on our website.

Last updated: [INSERT DATE]

Contact details

If you have any questions about this Privacy Policy or how we process your personal information, please contact:

Carly Ann Coaching Ltd
Carly Turner
Email: carly@carly-ann.co.uk

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