Legal
Privacy Policy
How Elements of Mind Therapy collects, uses, and protects your personal data.
Last updated: July 2026 — This policy is compliant with UK GDPR, the Data Protection Act 2018, and the Data (Use and Access) Act 2025.
1. Who We Are
Elements of Mind Therapy is a sole practitioner therapy practice operated by David Gowans, based in Inveraray, Argyll, Scotland. For the purposes of data protection law, David Gowans is the Data Controller.
Contact: david@elements-of-mind.co.uk | +44 7999 007902 | elements-of-mind.co.uk
2. What Data We Collect
We may collect and process the following categories of personal data: Name, date of birth, and contact details (email, phone, address); Health, medical history, and mental health information relevant to your sessions; Session notes and therapeutic records; Payment and billing information; Communications sent to us by email, phone, or via this website; Technical data such as IP address and browser type when you visit this website.
3. How We Use Your Data
Your personal data is used to: deliver and manage your therapy sessions; maintain clinical records as required by professional standards; communicate with you about appointments and your care; process payments; meet our legal and safeguarding obligations; improve the quality and safety of our practice (anonymised only).
4. Lawful Basis for Processing
We process your data under the following lawful bases: Explicit consent (Article 9(2)(a) UK GDPR) for special category health and mental health data; Contractual necessity (Article 6(1)(b)) to deliver the services you have booked; Legal obligation (Article 6(1)(c)) where retention or disclosure is required by law; Legitimate interests (Article 6(1)(f)) for clinical supervision and practice improvement.
5. Special Category Data
Health and mental health information is classified as special category personal data under UK GDPR. It is afforded the highest level of protection, processed only with your explicit consent, stored securely, and never shared without your permission except where required by law or professional duty.
6. Who We Share Data With
We do not sell your data. We may share it only in the following circumstances: Clinical supervisor (on an anonymised basis as part of professional best practice); Legal requirement (where required by a court order or statutory authority); Safeguarding (where there is a serious risk to your safety or the safety of another person); Your GP or healthcare team (only with your prior consent, or in an emergency); Therasee, our practice management platform (GDPR compliant, ICO registered, UK/EU hosted).
7. Data Retention
Clinical records are retained for a minimum of 7 years from the date of your last session, or until a minor client reaches the age of 25 — whichever is later. After this period, records are securely destroyed. Financial records are retained for 6 years in line with HMRC requirements.
8. Your Rights
Under UK GDPR and the Data (Use and Access) Act 2025, you have the right to: access the personal data we hold about you (Subject Access Request); request correction of inaccurate data; request deletion of your data (subject to legal retention obligations); object to or restrict certain processing; raise a data protection complaint directly with us (we will respond within 30 days); complain to the Information Commissioner (ICO) at ico.org.uk.
To exercise any of these rights, contact: david@elements-of-mind.co.uk
9. Cookies & This Website
This website uses Google Fonts, which is loaded from Google's servers and may set cookies or log your IP address. No other tracking, analytics, or advertising cookies are used. You can disable cookies in your browser settings at any time. We do not use Google Analytics or any other tracking service on this website.
10. Data Security
All client records are stored securely using Therasee, a GDPR-compliant, ICO-registered practice management platform hosted in UK/EU data centres. Communications by email are encrypted in transit. Paper records, if any, are stored in a locked location and destroyed securely when no longer needed.
11. Changes to This Policy
This policy may be updated from time to time. The date at the top of this page shows when it was last revised. Continued use of our services after any changes constitutes acceptance of the updated policy.
12. Contact
If you have any questions about this Privacy Policy or how we handle your data:
David Gowans
Elements of Mind Therapy
Inveraray, Argyll, Scotland
david@elements-of-mind.co.uk
+44 7999 007902