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Alana Holland Hypnotherapy
ICO privacy notice
This privacy notice is a breakdown of what you expect me to do with your personal information.
· What information we collect, use, and why
· Lawful bases and data protection rights
· Where we get personal information from
· How long we keep information
Contact details
Telephone : 07789796488
Email : alana@alanahollandhypnotherapy.co.uk
What information I collect, use, and why
In May 2018 the Data Protection Act was replaced by the General Data Protection Regulations (GDPR). The changes to the Data Protection Act are aimed at ensuring that your personal, confidential and sometimes sensitive data, is held privately and
securely.
I collect or use the following personal information To provide client services, hypnotherapy and psychotherapy:
· Name, address and contact details
· Date of birth
· Emergency contact details
· Health information (including medical conditions)
Lawful bases and data protection rights
Under UK data protection law, I 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:
· 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.
· 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.
· Your right to erasure – You have the right to ask us to delete your personal information. Read more about the right to erasure.
· 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.
· 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.
· 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.
· Your right to withdraw consent – When I use consent as my 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, I must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact me using the contact details at the top of this privacy notice.
My lawful bases for the collection and use of your data:
My lawful bases for collecting or using personal information to provide client services, hypnotherapy and psychotherapy are:
- Legitimate interests – I collecting your information because it benefits you, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.
My legitimate interests are:
I need to gather relevant information from a client regarding any health conditions that can be worked on during hypnotherapy. In order to understand what a client’s issues are, certain questions need to be asked regarding some physical or mental conditions so the client would be best to confirm if they have any of the conditions asked about to assist with the therapy. This information is purely optional, and to benefit the client during sessions.
For more information on my use of legitimate interests as a lawful basis you can contact me using the contact details set out above.
Where I get personal information from
Directly from you
How long I keep information
I am bound by my insurers agreement to hold on to personal information for an adult 18 years and over for 7 years. I will retain information for a 7 year period.
The client can request deletion at any time by emailing me the request.
Duty of confidentiality
I am subject to a common law duty of confidentiality. However, there are circumstances where I will share relevant health and care information. These are where:
· you’ve provided me with your consent (I have taken it as implied to provide you with care, or you have given it explicitly for other uses);
· I have a legal requirement (including court orders) to collect, share or use the data;
· 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);
· If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
· If in Scotland – I 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.
How to complain
If you have any concerns about my use of your personal data, you can make a complaint to me using the contact details at the top of this privacy notice.
If you remain unhappy with how I have used your data after raising a complaint with me, 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
Website: https://www.ico.org.uk/make-a-complaint
The Data Uses and Access Act (2025) has led to some amendments to UK GDPR.
1. ‘Lawful Bases.’ As therapists we will be processing personal information about our clients and in our Privacy Policy we will state our lawful basis for doing so. This has been the case since 2018. There are 7 lawful bases. The lawful basis most likely to apply to us as therapists is ‘legitimate interests’ which should be clearly explained in your Privacy Policy by explaining purpose, necessity and balance. A Privacy Policy should state:
a. the genuine purpose for obtaining personal information from clients and prove that processing is necessary (processing means collecting, storing, viewing, erasing etc. personal information).
b. necessity, i.e. you only collect personal information that is necessary to the work that you are doing with the client.
c. balance; meaning that you only collect necessary personal information with minimal impact on privacy. For example, it is likely to be necessary to record a client’s contact number, or safeguarding information (emergency contact or address), but to record their relationship status and the names and ages of their children might not be necessary.
What has changed? The DUAA (2025) has now added ‘recognised legitimate interests’ lawful basis. When you use personal information for certain ‘recognised legitimate interests’ it removes the need for you to balance the impact on an individual against the benefits of that use e.g. when protecting public safety. For example, the change now allows you to give personal information to organisations such as the police without you having to make a judgement about the necessity. The organisation making the request is responsible for this decision.
2. SARS (Subject Access Requests). It is possible that as a therapist you may be in receipt of a SAR; a client asking for access to the personal information you process on them.
What has changed? The DUAA (2025) clarifies that you only need to make ‘reasonable and proportionate’ searches when someone asks for access to their personal information. You are not required to check every single document/email, etc. if the information is unlikely to contain relevant data or is disproportionately difficult.
*If you are in receipt of a SAR contact the Head of Professional Standards who will be able to signpost and support you through the process.
3. NEW: Data Protection Complaints. DUAA (2025) requires you to take steps to help clients who want to make a complaint about how you have used their personal information, for example, by providing an electronic complaints form. Your Privacy Policy and complaints form should be easily accessible on your website and a link/copy should be shared with new clients to make access as easy as possible. The ICO states:
This section introduces a right for people to complain to organisations and competent authorities if they think that they’ve used their personal information in a way that doesn’t comply with the law.
It places an obligation on organisations and competent authorities to help people to make complaints, requiring them to take steps such as providing an electronic complaints form.
They must acknowledge complaints within 30 days and advise the complainant of the outcome without undue delay. They must also take appropriate steps in the meantime, such as making enquiries into the subject matter of the complaint and keeping the complainant informed about progress.
A client must field their complaint via the therapist’s complaint process first. If the client is dissatisfied with the outcome, they have the right to escalate their complaint to the ICO.
The complaints procedure only needs to relate to a complaint in the way in which a client’s personal data is used i.e. this does not relate to a general complaint about a therapist’s practice and/or professionalism which does not have to go through the therapist first and can be made anonymously through their professional association.
Your complaints process needs to be in place by 19th June 2026.
If you have any queries please contact our Head of Standards at standards@afsfh.com
Further Information: