Privacy Policy

1. What You Can Expect to See From Reading This Privacy Policy

The International Psychology Clinic Ltd respects the privacy of every individual who visits its website. Your data will be treated in accordance with relevant European Union legal provision.

The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.

The purpose of this privacy policy is to describe how we use personal data of individuals who access our therapeutic services and/or use our website, and informs you of your data protection rights.

Mind a Porter does not use cookies to directly collect personal information. We present a cookie consent banner to meet PECR requirements; by accepting categories you consent to storage on your device. You can manage preferences at any time via the banner. Disabling cookies may impact functionality and your experience on mindaporter.com.

2. Data Protection – What You Should Know When Accessing Our Therapeutic Services and/or Using Our Website

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The International Psychology Clinic Ltd keeps confidential records and statistics about its clients. This applies equally to information accessed when services are provided in person or online. Mind a Porter is committed to protecting the privacy of all its users.

The Data Controller is The International Psychology Clinic Ltd. Whilst the practitioner treating you is the controller of any health information you provide to them in the course of your treatment, we are the Controller in respect of any personal data you provide to us when you book an appointment or access our website.

3. Who We Are

Who We Are: The International Psychology Clinic Ltd (trading as "Mind a Porter"). Registered office: Unit 29, Highcroft Industrial Estate, Horndean, Waterlooville, Hants. PO8 0BT. Company number: 10877544. In this Privacy Policy, "Mind a Porter", "we", "our", or "us" refers to The International Psychology Clinic Ltd (t/a Mind a Porter).

What this Privacy Policy covers: This Privacy Policy covers our website mindaporter.com and our professional services.

Storage and International Transfers: We primarily store data in the UK/EEA. Where transfers outside the UK/EEA are necessary (e.g., to sub‑processors), we implement appropriate safeguards such as the UK International Data Transfer Addendum and EU Standard Contractual Clauses, ensure destinations have adequate protection, and apply additional measures where needed (see Section 11).

How we are regulated: For UK data protection legislation purposes, The International Psychology Clinic is registered with the Information Commissioner's Office (ICO) under registration number ZA317206.

Customer Relationship Centre contact details: If you would like to get in touch on a service or website related query, you can contact us by using the Contact Us link on the website.

4. Why Do We Need to Collect and Store Personal Data?

In order for us to provide you with access to our therapeutic services and/or to use our website we need to collect personal data for correspondence purposes and/or to provide you with access to our therapeutic services. In any event, you are under no statutory or contractual obligation to provide this data to The International Psychology Clinic Ltd however failure to do so may impact on services we are able to offer you.

4A. Categories of Personal Data We Collect and Sources

We collect personal data that you provide directly via forms on our website, booking and intake flows, email/SMS/phone, and (where applicable) social channels; we also generate data from your usage of our services and website.

• Identity and contact: name, preferred identity, date of birth/age, address, email, telephone/SMS number (with your permissions for SMS/voicemail), occupation, relationships & dependants.
• Service information: counselling/therapy history, presenting difficulties, goals, appointment/booking history, preferences (e.g., language, format), consent preferences.
• Health (special category) data: medical/mental health information relevant to therapy, prescribed medication, and screening questionnaires (e.g., PHQ‑9, GAD‑7) where provided.
• Payments/administration: billing details necessary to process payments and invoices (handled via our payment processor).
• Marketing preferences: your choices about receiving updates, promotions, and newsletters.
• Technical/usage: device, browser, IP address, and interactions collected via analytics and server logs (see "Website Analytics and Server Logs").

We aim to ensure data are accurate, relevant, and not excessive for the purposes described in this policy.

5. How Will We Use the Personal Data About You?

We process personal data for certain legitimate business purposes, which include some or all of the following:

• where you have subscribed to our email list, sending you updates and information or other marketing or promotional materials
• where you have indicated your interest in our services, sending you information or marketing materials you have signed up to receive
• seeking your thoughts and opinions on the services we provide
• notifying you of any changes to our services that may affect you
• improving our services, including by enhancing existing services and developing new services; and
• improving our website, including ensuring content is presented in the most effective manner for you and your device.

Additionally, we may process personal data where the processing is necessary for compliance with a legal obligation to which we are subject.

6. What Legal Basis Do We Have for Processing Your Personal Data?

The collection of personal data is necessary for the performance of the contract we have with you or to respond to your enquiries and requests. Where we collect personal data that is not necessary for the performance of a contract with you, then that data will only be collected and processed where you have consented or where it is in our legitimate interests and your interests and fundamental rights do not override those interests.

• Contract: to register you, provide services, schedule/manage appointments, and process payments/invoices.
• Legitimate interests: to operate, secure, and improve our services; respond to enquiries; and prevent fraud (balanced against your rights).
• Consent: for optional activities such as marketing communications and for processing special category data where required; you can withdraw consent at any time.
• Legal obligation: to comply with applicable laws, regulatory, tax, and accounting requirements.

Special category data (health): where we process health information relevant to therapy, we do so under UK GDPR Article 9(2)(a) (your explicit consent) and/or Article 9(2)(h) (health or social care) as applicable, with appropriate safeguards.

Consent and withdrawal: where we rely on consent, you can withdraw it at any time by using the Contact Us link or email in this policy. Withdrawal does not affect processing already carried out and may impact our ability to deliver certain services.

7. Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. The International Psychology Clinic Ltd uses third-parties to provide the below services and business functions, however all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

We may share your personal information with the following third parties:

• Professional advisers including lawyers and accountants
• IT service providers who support our systems
• Payment processors to handle transactions
• Marketing service providers
• Regulators and other authorities where required by law

8. How Long Do We Keep Your Personal Data?

The International Psychology Clinic Ltd (t/a Mind a Porter) retains personal information only for as long as necessary for the purposes set out in this policy. We are required under UK tax law to keep basic personal data (name, address, contact details, invoices) for a minimum of 6 years, after which it will be securely deleted unless we are required to keep it longer by law.

Marketing information is retained until you withdraw consent or opt out. You can unsubscribe from marketing communications at any time by emailing us or by clicking the unsubscribe link in any marketing email.

Clinical records: individual therapists engaged by you are independent data controllers for clinical notes and health information. In line with professional obligations, clinical records are typically retained for 7 years (and, for minors, until age 25). Mind a Porter does not store or manage these clinical records. Requests relating to clinical notes must be directed to your therapist (see "Clinical Records and Data Controller Responsibility" below).

9. Providing Us With Your Personal Data

You may choose to restrict the collection or use of your personal data by not consenting to certain processing activities when given the option. However, this may prevent us from providing you with certain services and you may not be able to gain full access to our website.

10. Safeguarding Measures

The International Psychology Clinic Ltd takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:

• SSL encryption
• Pseudonymisation (in some circumstances)
• IT authentication
• Restricted access

11. International Transfers

In some limited circumstances we may need to transfer your information outside the UK and/or European Economic Area (EEA) in order to provide our services to you. In such cases, we will comply with applicable UK and EU laws designed to ensure the privacy of your personal information, which may include:

• Implementing appropriate contractual safeguards, including standard contractual clauses
• Ensuring the recipient is in a country with adequate data protection laws as recognised by the EU Commission
• Ensuring the recipient has appropriate safeguards in place

12. Consequences of Not Providing Your Data

You are not obligated to provide your personal information to The International Psychology Clinic Ltd, however, as this information is required for us to provide you with our services and manage our relationship with you, we will not be able to offer some or all of our services without it.

13. Legitimate Interests

As noted in Section 6 above, we may from time to time process your personal information under the legitimate interests' legal basis. Where this is the case, we have carried out a legitimate interests assessment to ensure that we have weighed your interests and any risk posed to you against our own interests, ensuring that they are proportionate and appropriate.

Some typical examples of when we might use this legal basis are:

• Communicating with you to respond to your queries or requests
• For fraud prevention and detection
• Where we are required to do so by law or regulation
• To enforce our legal rights or to defend ourselves against legal claims

14. Your Rights

You have the right to access any personal information that The International Psychology Clinic Ltd processes about you and to request information about:

• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

We aim to respond to verified requests within 30 calendar days. We may require proof of identity (e.g., passport or driving licence) and proof of address. Our response will describe the personal data we hold and, where applicable, include copies and a schedule describing categories, purposes, recipients, and retention.

15. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works.
• Functionality cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences.
• Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website. You can also manage consent by category via our cookie banner at any time.

15A. Website Analytics and Server Logs

Whenever you browse mindaporter.com, read pages, or download information, our systems may automatically record certain information about your visit for security and analytics. This information does not directly identify you and helps us improve our site.

• Date/time of access and session duration
• Pages viewed and referring website
• IP address, Internet domain, browser type, and operating system
• General location inferred from IP (at coarse level)

We use this information to secure the site, diagnose issues, measure performance, and improve content. You can control analytics cookies via our cookie consent banner and your browser settings.

16. Lodging a Complaint

The International Psychology Clinic Ltd only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113
Website: www.ico.org.uk

16A. Protection of Email Addresses

Your email address is used only to respond to your enquiry unless you have explicitly consented to receive marketing communications. You can withdraw marketing consent at any time using the methods described in this policy.

17A. Links to Other Websites

Our website may contain links to websites run by other organisations that we do not control. This policy does not apply to those sites. We encourage you to read their privacy statements. We are not responsible for their content, privacy practices, or terms.

17B. Embedded Content from Other Websites

Articles on this site may include embedded content (e.g., videos, images, articles). Embedded content from other websites behaves in the exact same way as if you visited the other website and may collect data about you, use cookies, and monitor your interaction, including if you are logged in to that website.

17C. Comments and Media Uploads

We do not currently provide public commenting or user media uploads on our website. If these features are introduced in the future, this policy will be updated to describe any additional processing, including spam detection and EXIF location data considerations.

18. Clinical Records and Data Controller Responsibility

All therapists working with Mind a Porter are independent, self‑employed practitioners. Each practitioner acts as the data controller for the clinical records of their own clients and is fully responsible for storing, managing, and responding to any access requests related to those records. Mind a Porter does not store, manage, or have access to clinical notes or personal health information created or held by these independent therapists. If you wish to access your clinical records, exercise data rights under GDPR, or raise a concern regarding your personal data processed as part of your therapy, please contact your individual therapist directly. Mind a Porter cannot respond to such requests, as it is not the data controller for this information.

17. Contact Us

If you have any questions about this Privacy Policy or wish to exercise any of your rights, please contact us at:

The International Psychology Clinic Ltd
Email: hello@mindaporter.com