Phoenix Therapy Norfolk customer privacy notice (updated 8th November 2026)

This privacy notice tells you what to expect us to do with your personal information.

• Contact details
• What information we collect, use, and why
• Lawful bases and data protection rights
• Where we get personal information from
• How long we keep information
• Who we share information with
• Sharing information outside the UK
• How to complain

Contact details

Email: emma@phoenixtherapynorfolk.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:

• Name, address and contact details
• Gender
• Pronoun preferences
• Date of birth
• Next of Kin details including any support networks
• Emergency contact details
• Health information (including medical conditions, allergies, medical requirements and medical history)
• Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)
• Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
• Records of meetings and decisions
• 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:

• Health information
• Sexual orientation information

We collect or use the following information for safeguarding or public protection reasons:

• Name, address and contact details
• Emergency contact details
• Health information (including medical conditions, allergies, medical requirements and medical history)
• Information about care needs (including disabilities, home conditions, dietary requirements and general care provisions)
• Relevant information from previous investigations
• Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
• 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:

• Health information

We collect or use the following personal information for patient app or portal functionality:

• Names and contact details

We collect or use the following personal information to comply with legal requirements:

• Name
• Contact information
• Financial information
• 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:

• Health information
• Sexual orientation information

We collect or use the following personal information for information updates, marketing or market research purposes:

• Names and contact details
• Marketing preferences
• Records of consent, where appropriate

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
• Addresses
• Payment details
• Purchase or service history
• Call recordings
• Customer or client accounts and records
• Financial transaction information
• 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:

• 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:

• 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 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:

• 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.
• 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.
• 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:

• 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.
• 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:

• 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.
• 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 to comply with legal requirements are:

• 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.

Our lawful bases for collecting or using personal information for information updates, marketing or market research purposes are:

• 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.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• 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.
• 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.

Where we get personal information from

• Directly from clients
• Family members or carers
• Other health and care providers
• Social services
• Charities or voluntary sector organisations
• Schools, colleges, universities or other education organisations
   

How long we keep information

Client data is stored while clinical involvement is active i.e. sessions are ongoing. Client data includes, for example, data about the person receiving sessions or having been assessed, as well as any information from family members. Once sessions or involvement with the client comes to an end, data is archived and kept for 5 years if over 18 years of age, or for 5 years after the client's 18th birthday - information is retained for this length of time after client involvement in case of the data being required to contribute towards investigations or reviews e.g. understanding the chronology to inform a safeguarding investigation, or completing tax audits. After this period of time, the data is destroyed. 
 

Who we share information with

Data processors

Google (Google Workspace - data storage)

This data processor does the following activities for us: Stores data on professional workspace including email. 

Data (all but information stored on email) is in the process of being migrated through November 2026 to WriteUpp (see below). Data received or sent via email will remain on the Google Mail until data is manually deleted or the client data is archived. 

WriteUpp

From November 2026, this data processor does the following activities for us: Stores data held about clients including personal information (e.g. name, contact information), clinical notes, appointment dates and times, consents received, session payments. 

WriteUpp was chosen as Phoenix Therapy Norfolk's new client data platform partly because of their commitment to GDPR protection. 

PatientNotes

This data processor does the following activities for us: Records client sessions, transcribes and produces clinical notes and documentation from the recordings. Stores the session data for a maximum of 30 days, before which time the clinical note and transcription is transferred to Google Workspace or WriteUpp as above from November 2026. 

Others we share personal information with

• Other health providers (eg GPs and consultants)
• Charities and voluntary organisations
• Care providers
• Organisations we need to share information with for safeguarding reasons
• Emergency services
• Local authorities or councils
• 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:

• 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);
• we 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 – 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: Google

Category of recipient: Storage provider on Google Workspace

Country the personal information is sent to: United States of America

How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)
 

Organisation name: WriteUpp

Category of recipient: Storage provider and data processor

Country the personal information is sent to: Dublin, European Union

How the transfer complies with UK data protection law: ISO27001 certified. 

Organisation name: PatientNotes

Category of recipient: Storage provider, data processor

Country the personal information is sent to: Australia

How the transfer complies with UK data protection law: Data Processing Agreement (DPA)
 

How to complain

If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

Email: emma@phoenixtherapynorfolk.net

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 
Website: https://www.ico.org.uk/make-a-complaint