Our Privacy Policy

We are Doctor Divergent, providing individual therapeutic support and organisation educational and support for neurodivergent colleagues.

Our website address is: http://www.doctordivergent.co.uk.

Your privacy is important to me. Your personal information will be kept safe and secure and will only be used for the purpose that it was given to me. Jacqueline Haworth trading as Doctor Divergent Ltd adheres to current data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, Data Use and Access Act 2025 (DUAA), and the Privacy and Electronic Communications (EU Directive) Regulations (PECR) 2003.

This privacy policy outlines what I will do with your personal information from the initial point of contact through to after your therapy has ended, including:

• Why I am able to process your information
• The purpose I am processing it for
• Whether you have to provide it to me
• How long you data is stored
• Whether there are other recipients of your personal information
• Your data protection rights.

‘Data controller’ is the term used to describe the person/organisation that collects and stores and has responsibility for people’s personal data. In this instance, the data controller is Dr Jacqueline Haworth.

Lawful basis for holding and using your personal information

In order to provide you with counselling services I will need information from and about you. Information about you will only be used in ways that are core or legally essential for me to fulfil my role as an effective, ethical, safe and responsive counsellor to you.

UK GDPR states that organisations must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which your data is being processed. These are outlined below: 

• If you are currently having therapy or if you are in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of our contract
• If your therapy has concluded, I will use legitimate interest as my lawful basis for holding and using your personal information

The UK GDPR also has specific requirements detailing any sensitive personal information (Article 9) that you may disclose to me during the course of therapy. This type of information is called ‘special category personal information’. This includes:

• personal data revealing racial or ethnic origin
• personal data revealing political opinions
• personal data revealing religious or philosophical beliefs
• data concerning trade union membership/employment
• data concerning health
• data concerning a person’s sex life
• data concerning a person’s sexual orientation

This information is often disclosed during sessions and is helpful in delivering care/therapy. An additional lawful basis is required for the processing of special category of personal data. These are:

• (a) Explicit consent
  • I will have your consent to process this information when you disclose
• (h) Health or social care (with a basis in law)
  • For provision of health treatment (in this case counselling)

How do I obtain your personal data?

I will collect your personal information in the following ways:

• via my website (www.doctordivergent.co.uk)
• over the telephone
• via email
• over a messaging service (WhatsApp/SMS)
• in person during our sessions

Why do I need your personal information and what am I doing with it?

Your personal information helps guide my assessment process, my clinical decision-making during counselling and allows for the safe and effective delivery of care.

How I use your information

Your personal data is only used for the administration of the counselling service that I am providing to you.

Initial contact

When you submit an enquiry about counselling services I will collect information to help me satisfy your enquiry. This will include your name, telephone number and email address.

Alternatively, your GP or other health professional may send me your details when making a referral with your consent. 

If you decide not to proceed, all your personal data is deleted within 28 days.

If you would like me to delete this information sooner, please let me know. 

While you are accessing counselling

If you agree to contract for counselling services, information will be collected to ensure safe and effective delivery of the service. This will include your:

• Name
• Address
• Date of birth
• Contact information including telephone number and/or email address
• An emergency contact name and telephone number
• Your GP name and contact details
• Relevant medical and health information
• Information about any disability or communication difficulty you may have
• Session notes¹
• Payment information²

Everything you discuss with me during the course of our therapeutic relationship is confidential and I adhere to the British Association for Counselling and Psychotherapy (BACP) Ethical Framework. Your contact information is kept electronically within a secure, encrypted and password protected folder. A client reference number will be assigned to your details.

For security reasons I do not retain text (WhatsApp/SMS) messages for more than 28 days. If there is relevant information contained in a text message that is needed for administrative purposes (i.e. scheduling) or that is relevant to your clinical care, an electronic copy will be made and securely saved within your record.

Any email correspondence will be deleted after 28 days if it is not relevant for an ongoing purpose. If there is relevant information contained in an email that is needed for administrative purposes (i.e. scheduling) or that is relevant to your clinical care, an electronic copy will be made and securely saved within your record.

After counselling has ended

Once counselling has ended, your contact information will be deleted within 28 days of the last appointment or when any outstanding fees have been paid, whichever is later.

I am required to keep a record of your name, date of birth and client reference number for 7 years after therapy ends. This will be kept electronically within a secure, encrypted folder. Brief session notes will also be retained separately in an encrypted folder. Your client reference number corresponds with a client reference number on your therapy notes and therefore enables me to identify your therapy notes if necessary. All records will be securely deleted after this time.

Do I share your information with anybody?

As part of my professional responsibilities under the BACP I am required to have regular supervision with another professional counsellor. Personal identifying information about my clients is not disclosed within supervision.

If it is essential to protect your health and if I obtain your consent, I may share your contact information and relevant medical information with an emergency healthcare service (e.g. GP / ambulance).

In exceptional circumstances I may be required by law and ethical responsibilities to break confidentiality with you. I would discuss this with you first wherever possible but if you do not give consent I may still have to disclose information depending on the indication. This relates to situations where you may be at serious risk of harm, causing serious harm to others, the safeguarding of children and adults at risk, offences under the Prevention of Terrorism Act 2000, serious crime under the Serious Crime Act 2007, drug trafficking or money laundering and road traffic accidents under the Road Traffic Act 1991 where I am under legal obligations.

Some of your personal information such as website visits, telephone call data, or payment information, is shared with the website provider (Bluehost), mobile phone operator, bank or card payment provider respectively. These providers operate under their own privacy policies and these can be provided upon request.

A limited amount of personal details will be shared with third parties to fulfil legal obligations in respect of tax and accounting purposes. For example, accounting services are permitted access to invoices.

If your appointments are paid for or arranged via a third party, e.g. your employer, the only information shared with the third party are the dates of attendance/non-attendance for invoicing and payment purposes. The content discussed in your appointments will remain confidential and can only be shared if you provide me with your written consent to do so.

In the event of my own serious illness or death I have appointed a trusted colleague to have confidential access to your contact details for the purpose of notifying you and making arrangements for your further care.

I will never share your contact details with any third party organisations for the purposes of sales, marketing or research.

What are your rights? Who would you complain to if you have concerns?

As a data subject you have the following rights:

• To be informed what personal information I hold (i.e. this document)
• To see the personal information I hold about you. (i.e. Subject Access Request)
• To rectify any inaccurate or incomplete personal information
• To withdraw consent to me using your personal information
• To request your personal information be erased. (Right to Erasure)³
• To receive the personal information which you previously provided and the right to transfer that information to another party

In short this means that you have a right to ask me for a copy of any information that I hold about you and to object to the use of your personal data in some circumstances. You can also ask me to limit how I use your personal information, to delete your personal information, or to stop processing your personal information. It is important that the data we hold about you is accurate and up to date. Please keep us informed if your data changes during the period for which we hold it.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may refuse to provide, or charge a reasonable fee for collating this data if your request is clearly unfounded, repetitive or excessive.

You can read more about your rights at ico.org.uk/your-data-matters.

If you wish to exercise your rights, have any questions or wish to make a complaint please email [email protected]

If you want to make a formal complaint about the way I have processed your personal information you can contact the Information Commissioners Office (ICO). This is the body that oversees data protection law in the UK. For more information go to ico.org.uk/make-a-complaint

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Changes to this privacy policy

I may update this privacy policy from time to time. Changes to this privacy policy are effective when they are posted on this page. You are therefore advised to review this privacy policy periodically for any changes.