Apex Therapy & Coaching Privacy Notice
This privacy notice tells you what to expect us to do with your personal information.
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Contact details
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What information we collect, use, and why
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Lawful bases and data protection rights
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Where we get personal information from
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How long we keep information
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Who we share information with
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Sharing information outside the UK
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How to complain
Contact details
Telephone 01244 727 625 or 07821 569 177
Email apextherapy@therapist.net
What information we collect, use, and why
We collect or use the following information to provide patient care, services, pharmaceutical products and other goods:
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Name, address and contact details
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Pronoun preferences
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Date of birth
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Next of Kin details including any support networks
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Health information (including medical conditions, allergies, medical requirements and medical history)
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Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)
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Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
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Payment details (including card or bank information for transfers and direct debits)
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Records of meetings and decisions
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Call recordings
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Information about income and financial needs for funding or personal budget support
We also collect the following special category information to provide patient care, services, pharmaceutical products and other goods. This information is subject to additional protection due to its sensitive nature:
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Racial or ethnic origin
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Religious or philosophical beliefs
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Health information
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Sex life information
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Sexual orientation information
We collect or use the following personal information for the prevention, detection, investigation or prosecution of crimes:
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Name, address and contact details
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Video recordings of private or staff only areas (including staff rooms, offices, surgical areas, consultation areas and outside spaces to which only staff or patients have access)
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Audio recordings of private or staff only areas (including staff rooms, offices, surgical areas, consultation areas and outside spaces to which only staff and patients have access)
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Witness statements and contact details
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Relevant information from previous investigations
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Financial information eg for fraud prevention or detection
We also collect the following special category information for the prevention, detection, investigation or prosecution of crimes. This information is subject to additional protection due to its sensitive nature:
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Racial or ethnic origin
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Health information
We collect or use the following information for safeguarding or public protection reasons:
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Name, address and contact details
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Emergency contact details
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Health information (including medical conditions, allergies, medical requirements and medical history)
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Information about care needs (including disabilities, home conditions, dietary requirements and general care provisions)
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Relevant information from previous investigations
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Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
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Records of meetings and decisions
We also collect the following special category information for safeguarding or public protection reasons. This information is subject to additional protection due to its sensitive nature:
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Racial or ethnic origin
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Religious or philosophical beliefs
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Health information
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Sex life information
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Sexual orientation information
We collect or use the following personal information for patient app or portal functionality:
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Names and contact details
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Addresses
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Medical history
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Payment details
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Account information, including registration details
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Marketing preferences
We also collect the following special category information for patient app or portal functionality. This information is subject to additional protection due to its sensitive nature:
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Health information
We collect or use the following personal information to comply with legal requirements:
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Name
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Contact information
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Health and safety information
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Financial information
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Any other personal information required to comply with legal obligations
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Insurance details
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Tax information
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Safeguarding information
We also collect the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:
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Racial or ethnic origin
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Health information
We collect or use the following personal information for information updates, marketing or market research purposes:
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Names and contact details
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Addresses
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Marketing preferences
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Website and app user journey information
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IP addresses
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Records of consent, where appropriate
We also collect the following special category information for information updates, marketing or market research purposes. This information is subject to additional protection due to its sensitive nature:
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Health information
We collect or use the following personal information for dealing with queries, complaints or claims:
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Names and contact details
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Addresses
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Payment details
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Account information
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Purchase or service history
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Witness statements and contact details
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Customer or client accounts and records
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Financial transaction information
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Information relating to health and safety (including incident investigation details and reports and accident book records)
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Correspondence
We also collect the following special category information for dealing with queries, complaints or claims. This information is subject to additional protection due to its sensitive nature:
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Health information
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
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Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
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Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
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Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
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Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
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Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
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Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
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Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods are:
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Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
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Legitimate interests - we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
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Using HubSpot to manage your client list, following up with past clients, or maintaining session notes to protect your professional interests in case of a complaint.
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For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
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Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Our lawful bases for collecting or using personal information for the prevention, detection, investigation or prosecution of crimes are:
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Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
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Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
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Apex Threapy & Coaching have a "legitimate interest" in preventing fraud (protecting client\'s income via Stripe\/Square) and indicating possible criminal acts to the authorities to protect Apex Therapy & Coaching\'s business or the public. Under recent UK updates (the Data Use and Access Act), the prevention of crime is now a "recognised legitimate interest."
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For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
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Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Our lawful bases for collecting or using personal information for safeguarding or public protection reasons are:
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Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
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Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
- Under the 2025 updates, safeguarding is now a "Recognised Legitimate Interest." This provides a clearer legal path for Apex Therapy & Coaching to share information to protect the well-being of a child or an "at-risk" adult, even if it doesn\'t meet the high bar of an immediate "vital interest.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
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Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Our lawful bases for collecting or using personal information for patient app or portal functionality are:
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Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
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Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
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Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
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The administrative and security aspects of the portal that benefit both Apex Therapy & Coaching and the client. It is in Apex Therapy & Coaching\'s "legitimate interest" to provide a secure login, prevent unauthorized access to billing data (via Stripe\/Square security features), and use administrative tools that make Apex Therapy & Coachung business efficient.
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For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information to comply with legal requirements are:
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Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
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Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
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This covers legal-adjacent activities that might not be a strict statutory duty but are necessary for legal protection. For example, keeping clinical notes against a future legal claim or insurance dispute is a "legitimate interest" (under the Statute of Limitations, which allows claims up to 6 or 7 years later).
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For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
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Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Our lawful bases for collecting or using personal information for information updates, marketing or market research purposes are:
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Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
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Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
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Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
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The "Soft Opt-in": If a client has recently finished therapy withApex Therapy & Coaching, Apex Therapy & Coaching can send clients information about similar services (like a new group workshop) without a fresh opt-in, provided Apex therapy & Coaching has given clients a clear chance to opt out when they first signed up.
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Market Research: Apex Therapy & Coaching may want to send a survey to improve our practice.
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For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
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Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
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Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
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Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
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Apex Therapy & Coaching have a legitimate interest in investigating complaints and defending ourselves against legal claims or professional conduct allegations. This allows Apex Therapy & Coaching to keep and review session records or emails in HubSpot even if the client has ended their relationship with us.
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For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
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Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Where we get personal information from
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Directly from you
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Family members or carers
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Other health and care providers
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N\/A
How long we keep information
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Data Type Retention Period Reason
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Clinical Session Notes 7 Years Recommended by insurers to defend
against legal claims (negligence/contract)
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Financial Records 6 Years + current year Required by HMRC for tax audit purposes.
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Inquiries (No Booking) 12 Months To allow for follow-up, but deleted
after if the person doesn't become a client.
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Email/SMS Correspondence 7 Years Kept alongside clinical notes
as part of the client's treatment record.
Marketing Consent Until withdrawn HubSpot keeps this as long as the Clients
are on Apex's list; This is deleted if the client unsubscribes.
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For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
Who we share information with
Joint data controllers
We have a joint controller relationship with Calendly. We process your personal information with that joint controller for the following reason: For scheduling and appointment management.
We also have a joint controller relationship with HubSpot. We process your personal information with that joint controller for the following reason For client relationship management (CRM) and communications..
We also have a joint controller relationship with Stripe, Inc. We process your personal information with that joint controller for the following reason for Financial Services and payment processing provide
We also have a joint controller relationship with Square Up Europe Ltd / Block, Inc. We process your personal information with that joint controller for the following reason for Financial Services and point-of-sale payment provider.
HubSpot, Inc. (CRM and Marketing Automation Software). Sector: Information Technology \/ SaaS. Location: Germany (EU) and USA.
This data processor does the following activities for us: They store our client contact records, communication history, and marketing preferences. They also host our contact forms and manage our email automation.
Calendly LLC (Online Scheduling Service). Sector: Information Technology \/ SaaS. Location: USA.
This data processor does the following activities for us: They manage our appointment booking system, collect initial screening information from clients, and synchronize our availability with our professional calendar.
Stripe Payments Europe, Ltd / Stripe, Inc. (Payment and Financial Services). Sector: Financial Services / FinTech. Location: Ireland (EU) and USA.
This data processor does the following activities for us: They process our credit and debit card transactions, manage secure recurring billing, and maintain financial records for tax and accounting purposes. They also handle advanced fraud detection and security screening to protect your financial information during the checkout process.
Square Up Europe Ltd / Block, Inc. (Payment and Point of Sale Services). Sector: Financial Services / FinTech. Location: Ireland (EU) and USA. This data processor does the following activities for us: They provide our secure payment processing for both in-person and remote sessions. They manage our transaction history and provide a secure platform for generating and sending digital receipts. They also store essential billing data required for our internal business reporting and HMRC tax compliance.
Others we share personal information with
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Other health providers (e.g. GPs and Consultants)
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Organisations we need to share information with for safeguarding reasons
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Emergency services
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Professional advisors
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Organisations we’re legally obliged to share personal information with
Duty of confidentiality
We are subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information. These are where:
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you’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
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we have a legal requirement (including court orders) to collect, share or use the data;
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on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
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If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
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If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.
Sharing information outside the UK
Where necessary, we will transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.
For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.
Organisation name: HubSpot, Inc
Category of recipient: Customer Relationship Management (CRM) and Marketing SaaS
Country the personal information is sent to: Germany (Primary hosting for UK\/EU) and United States (System administration and sub-processing).
How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)
Organisation name: Calendly LLC
Category of recipient: Online Appointment Scheduling SaaS.
Country the personal information is sent to: United States (Data is stored on Google Cloud servers primarily in the US).
How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)
Organisation name: Stripe Payments Europe, Ltd \/ Stripe, Inc.
Category of recipient: Payment Processing and Financial Services.
Country the personal information is sent to: Ireland (Primary for UK\/EU users) and United States (Global headquarters and fraud prevention processing)
How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)
Organisation name: Square Up Europe Ltd / Block, Inc.
Category of recipient: Payment Processing and Financial Services.
Country the personal information is sent to: Ireland (Primary for UK/EU operations) and United States (Global headquarters and sub-processing for security and platform maintenance).
How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge).
Where necessary, our data processors may share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.
For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.
Organisation name: HubSpot, Inc.
Category of recipient: Software as a Service (SaaS) provider for Customer Relationship Management (CRM) and Marketing.
Country the personal information is sent to: United States (and Germany for European data hosting).
How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)
Organisation name: Calendly LLC
Category of recipient: Software as a Service (SaaS) provider for online appointment scheduling.
Country the personal information is sent to: United States.
How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)
Organisation name: Stripe, Inc.
Category of recipient: Financial Services and payment processing provider.
Country the personal information is sent to: United States (and Ireland for European payment processing).
How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)
Organisation name: Square Up Europe Ltd / Block, Inc.
Category of recipient: Financial Services and payment processing provider.
Country the personal information is sent to: Ireland (Primary for UK/EU operations) and United States (Global headquarters and technical sub-processing).
How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge).
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
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If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113