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Privacy Policy

Version 2.1  |  Published 08/09/26

 

1. Introduction

 

Cherry Orchard Therapy Ltd is committed to protecting your privacy. This policy explains what personal information we collect, why we use it, how we keep it secure, when it may be shared, how long we keep it and the rights you have in relation to it.

This policy applies from your first contact with Cherry Orchard Therapy, throughout counselling, after the work has ended, and when you use our website.

2. Who we are

 

Cherry Orchard Therapy Ltd is the data controller for personal information processed as part of the services it provides.

Cherry Orchard Therapy is registered with the Information Commissioner’s Office, ZA549727.

 

Our postal address is: Cherry Orchard Therapy Ltd,

Office 1, 344 Croydon Road,

Beckenham, BR3 4EX

Our phone number is: 07426 810168

Our email address is: info@cherryorchardtherapy.com.

3. Information we collect

 

The information we collect depends on what is necessary to provide and administer our services. It may include:

  • name and contact details;

  • date of birth;

  • GP and emergency-contact details;

  •  information provided when you enquire about or are referred for counselling;

  • assessment information and information relevant to therapy;

  • appointment, attendance and communication records;

  • brief counselling session records;

  • payment, invoicing and financial-administration information; and

  •  information you choose to share during counselling.

 

Counselling may involve sensitive information which data-protection law calls special category data. This may include information about physical or mental health, racial or ethnic origin, religious or philosophical beliefs, sex life or sexual orientation. We do not routinely ask clients to provide diversity information simply for monitoring purposes, but information of this kind may arise naturally in therapy and may be recorded where relevant.

We normally obtain information directly from you. We may also receive information from a parent or carer, GP, healthcare professional, referrer or another person acting on your behalf.

4. Why we use your information and our lawful bases

 

We use personal information to respond to enquiries, assess and provide counselling, manage appointments and communications, process payments, maintain appropriate professional records, administer the practice, meet safeguarding and professional responsibilities, and comply with legal obligations.

When you contact us about counselling or receive counselling through Cherry Orchard Therapy, our principal lawful basis for ordinary personal information is that processing is necessary to take steps at your request before entering into a contract or to perform our contract with you.

After therapy has ended, we may retain appropriate records where this is necessary for our legitimate interests, including maintaining appropriate professional records and responding to future concerns, complaints or legal claims.

Counselling often involves special category information. Where this is necessary for the provision of counselling, Cherry Orchard Therapy processes it under the UK GDPR provisions relating to the provision of health care or treatment and associated duties of confidentiality. Different lawful conditions may apply in exceptional circumstances, including safeguarding, vital interests, legal claims or disclosures required by law.

Consent to counselling and therapeutic confidentiality are distinct from consent as a data-protection lawful basis. We do not rely on GDPR consent as the general basis for processing clinical information simply because you have agreed to receive counselling.

5. Confidentiality

 

What you discuss in therapy is treated as confidential. Information about you will only be accessible to people who need it in order to provide or administer your therapy.

Confidentiality is not absolute. There are limited circumstances in which information may need to be shared without your consent. These may include:

  • where there is a serious risk of harm to you or another person;

  • where there is a safeguarding concern involving a child or an adult at risk;

  • where disclosure is required by law, which may include certain information relating to terrorism, money laundering or other serious criminal matters; and

  • where we are required to comply with a court order or another legally enforceable requirement.

 

Where we are considering sharing information without your consent, we will normally seek appropriate consultation and, wherever possible and appropriate, discuss this with you first.

There are circumstances in which the law may require or permit us to disclose information without informing you. In some situations, informing you that a disclosure has been made, or is being considered, may itself be unlawful or may prejudice an investigation. In those circumstances we will comply with our legal obligations and may not be able to tell you about the disclosure.

Where information is shared, we aim to disclose only what is necessary and relevant to the circumstances.

Practitioners discuss clinical work in professional supervision. Clients are not ordinarily identified by name in supervision, and supervisors are themselves bound by professional confidentiality.

6. How we store and protect your information

 

We take reasonable steps to keep personal information secure and limit access to people who need it.

Counselling session notes held by Cherry Orchard Therapy are hard-copy records kept in secure locked storage at our premises. Identifying and contact information is kept separately where practicable.

Practitioners may keep anonymised personal process notes for reflective purposes. These are separate from Cherry Orchard Therapy’s official client record, must be stored securely and are destroyed when no longer needed.

Some administrative information, including contact details, appointments, emails, text messages and payment or accounting records, is held electronically using services required to operate the practice. Devices and accounts used to access client information are protected using appropriate security measures.

7. How long we keep information

 

We only keep personal information for as long as we have a legitimate reason to do so.

As a general rule, clinical records relating to adult clients are retained for seven years after therapy ends. Where a client was under 18 when therapy ended, clinical records will normally be retained until their 25th birthday.

Information may be retained for longer where there is a specific legal, regulatory, safeguarding, insurance or other legitimate reason. Information that is no longer required will be securely destroyed or deleted.

Different retention periods may apply to administrative, communications and financial records where there is no reason to retain them for the same period as the clinical record.

8. Who we share information with

 

We do not sell your personal information.

To provide and administer our services, Cherry Orchard Therapy uses trusted service providers which may process limited personal information on our behalf. These currently include:

  • Google, for email and calendar services;

  • Wix, for our website, booking and appointment functions and related services;

  • SumUp, Square and Wix Payments, for payment processing;

  • FreeAgent, for accounting and financial administration; and

  • telephone and mobile communication providers, where we communicate by telephone or text.

 

We aim to limit the information processed through these services to what is reasonably necessary for the relevant purpose.

We may also share relevant information where necessary for safeguarding, to prevent serious harm, to comply with law or a court order, or for another lawful reason. Depending on the circumstances, recipients may include emergency services, social care services, healthcare professionals, legal advisers or other relevant authorities.

9. International processing

 

Some service providers we use operate internationally, so personal information may sometimes be processed outside the UK. Where this occurs, appropriate safeguards must be in place in accordance with UK data-protection law.

10. Children and young people

 

Cherry Orchard Therapy provides counselling to some children and young people as well as adults.

When working with someone under 18, we explain in an age-appropriate way how their personal information will be used and the limits of confidentiality. Where appropriate, a parent or person with parental responsibility will also be involved in arranging and consenting to counselling.

Children and young people have privacy rights of their own. The extent to which a young person can make decisions about their counselling and personal information depends on their age, understanding and circumstances.

Information disclosed by a young person in counselling will not routinely be shared with their parent or carer. As with adult clients, confidentiality may need to be broken where there is a safeguarding concern, serious risk of harm or another legal reason for disclosure. Where it is necessary to share information, we aim to involve the young person wherever it is safe, appropriate and lawful to do so.

11. Website visitors and cookies

 

When you visit our website, certain technical information may be collected automatically. This can include information about your device, browser, IP address and how you use the website.

Our website is provided through Wix and uses cookies and similar technologies to operate securely and help us understand how the website is used.

Cookies are grouped into Essential, Functional, Analytics and Marketing categories. Essential cookies are required for the website to function and cannot be disabled. Other cookies are used according to the choices you make through our cookie banner.

When you first visit the website, you can Accept All, Decline All or choose your preferences through Cookie Settings. You can subsequently change your cookie preferences using the website’s cookie controls.

We use Wix’s built-in website analytics tools to understand website traffic and how visitors use the site. Where these tools rely on non-essential cookies, they are subject to your cookie choices. We do not currently use Google Analytics or Google Ads tracking on the website.

If you submit information through an enquiry, contact or booking form, we use the information you provide to respond to your enquiry, administer your booking or provide the service you requested.

12. Your data-protection rights

 

Depending on the circumstances and the lawful basis being used, data-protection law may give you rights to:

  • ask for a copy of personal information we hold about you;

  • ask us to correct inaccurate or incomplete information;

  • ask us to delete personal information;

  • ask us to restrict how we use information;

  • object to certain uses of your information; and

  • receive certain information you have provided to us in a portable format.

 

These rights do not apply in every circumstance. For example, we may need to retain information despite a request for deletion where we have a lawful reason or obligation to keep it.

If you wish to exercise a right, contact Cherry Orchard Therapy using the details published on our website. We may need to confirm your identity. We will respond within the timescales required by data-protection law, normally within one month.

13. Concerns and complaints about your information

 

If you have questions or concerns about how Cherry Orchard Therapy uses your personal information, please contact us first so that we have an opportunity to address them.

You also have the right to raise a concern with the Information Commissioner’s Office (ICO), the UK’s independent data-protection regulator.

14. Changes to this policy

 

We may update this privacy policy from time to time to reflect changes in our services, systems, law or professional guidance. The current version will be published on our website with the date it was last updated.

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