Privacy Policy

Unit 55, Enniskillen Business Centre, 21 Lackaghboy Road, Tempo Road, Enniskillen BT74 4RL

info@innerease.co.uk | 07765 143271 | www.innerease.co.uk

Last updated: July 2026

1. Introduction

Inner Ease Therapy is committed to protecting your privacy and handling your personal information with care, transparency, and respect. This Privacy Policy explains what personal information is collected when you visit this website, make an enquiry, or engage with therapeutic services — and how that information is used, stored, and protected.

This policy is written in plain language. If you have any questions about anything in it, please get in touch directly.

This policy is reviewed and updated as needed. The date at the top of this page indicates when it was last revised.

2. Who We Are

Inner Ease Therapy is operated by Warren Abercrombie, a sole practitioner providing counselling, occupational therapy, and clinical hypnotherapy services.

For the purposes of data protection legislation, Warren Abercrombie is the Data Controller responsible for your personal information.

Contact details:

Warren Abercrombie - Inner Ease Therapy

Unit 55, Enniskillen Business Centre

21 Lackaghboy Road, Tempo Road

Enniskillen BT74 4RL

Email: info@innerease.co.uk

Tel: 07765 143271

Website: www.innerease.co.uk

Inner Ease Therapy is registered with the Information Commissioner's Office (ICO Registration No. ZC083824).

Warren Abercrombie is registered with the Health and Care Professions Council (HCPC No. OT73299), the Royal College of Occupational Therapists (RCOT No. BT0814185), the National Counselling and Psychotherapy Society (NCPS No. NCS23-03519), and the National Hypnotherapy Society (No. HYP22-01061). All data handling is conducted in accordance with the professional and ethical standards of these registrations.

3. Legal Framework

Personal data is handled in accordance with:

The UK General Data Protection Regulation (UK GDPR)
The Data Protection Act 2018
The professional standards and ethical guidelines of the HCPC, RCOT, NCPS, and National Hypnotherapy Society

4. What Information Is Collected

4a. Information you provide directly

When you submit an enquiry form, book a 15 minute chat, or engage with therapeutic services, the following information may be collected:

Name, postal address, email address, and telephone number
Reason for enquiry
Information you share voluntarily in contact forms or direct communication
Special Category Data: health information, psychological history, presenting difficulties, current medication, previous professional or therapeutic support, GP contact details, emergency contact details, and clinical assessment information shared during intake (including the therapeutic agreement and intake form) and in the course of therapy

Special Category Data, which includes health and mental health information, is given a higher level of protection under UK GDPR. It is only collected where necessary and is handled with the utmost care.

4b. Information collected automatically

When you visit the website, certain technical information may be collected automatically through cookies and analytics tools, including:

IP address
Browser type and version
Device information
Pages visited and time spent on the site
Date and time of visits

This technical information is used solely to understand how the website is used and to improve its performance. It does not identify you personally. Full details are set out in the Inner Ease Therapy Cookie Policy.

5. How Your Information Is Used

Personal information collected through this website and in the course of providing services is used to:

Respond to enquiries and arrange appointments
Conduct the free 15-minute introductory call and assess suitability for services
Provide therapeutic services, including counselling, occupational therapy, and clinical hypnotherapy
Maintain accurate and secure clinical records in accordance with professional registration requirements
Communicate appointment reminders, scheduling changes, or important service information
Meet legal and professional obligations, including safeguarding duties and regulatory requirements

Personal information will not be used for marketing purposes, sold, rented, or shared with third parties for commercial purposes.

6. Lawful Basis for Processing

Personal data is processed under one or more of the following lawful bases:

Consent - where you have actively provided information and agreed to its use
Performance of a contract - to provide the therapeutic services you have requested
Legal obligation - where processing is required to comply with a legal duty
Legitimate interests - for example, maintaining records necessary for the safe and ethical delivery of services
Provision of health or therapeutic services - where applicable

For Special Category Data (health and mental health information), processing is carried out under Article 9(2)(h) of the UK GDPR, which permits the processing of health data for the provision of health or social care or treatment by a health professional subject to the obligation of professional secrecy.

Warren Abercrombie is a registered health professional (HCPC) and is bound by professional confidentiality obligations under the standards of the HCPC, RCOT, NCPS, and National Hypnotherapy Society.

7. Clinical Records & Note-Taking

As an HCPC-registered health professional, Warren Abercrombie is required to maintain accurate and contemporaneous clinical records. The following describes how clinical notes and records are created and stored:

Session notes

Session notes are written during or immediately after appointments directly into secure digital records on an encrypted, password-protected work laptop. No separate note-taking devices are used.

Digital records

All clinical records are stored within a Google Workspace business account. Google Workspace is a GDPR-compliant platform operating under a Data Processing Agreement with Google LLC. Data is stored on Google's UK/EU infrastructure and is subject to Google's enterprise-grade security and access controls.

The Google Workspace account is accessible only to Warren Abercrombie and is protected by strong password authentication and two-factor authentication.

Paper records

Any paper documents, such as signed consent forms or correspondence received in paper format, are scanned to the secure Google Workspace account and then securely shredded. No paper records are retained indefinitely.

Online session records

Online therapy sessions are conducted via Google Meet, accessed through the Google Workspace business account. Sessions are not recorded unless explicit written consent is given in advance. Google Meet is covered by Google's Data Processing Agreement and processes data in accordance with UK GDPR.

8. Third-Party Data Processors

The following third-party platforms are used in the operation of Inner Ease Therapy and may process personal data on our behalf. All are engaged under appropriate data processing agreements and operate in compliance with UK GDPR:

Wix (website, contact forms, and therapeutic agreement)
The Inner Ease Therapy website is hosted on Wix Studio Plus. Enquiry forms, appointment bookings, and the therapeutic agreement and intake form submitted through the website are processed by Wix. Wix operates under enhanced GDPR compliance terms as part of the Studio Plus subscription and acts as a data processor. Wix's privacy practices are available at wix.com/about/privacy. Wix may store data in data centres in a number of locations, including the United States and Ireland; any transfers outside the UK/EU are safeguarded by Standard Contractual Clauses and additional technical and organisational measures, as set out in Wix's Data Processing Agreement.

Google Workspace (records, email, and video sessions)

Google Workspace is used for email communication, clinical record storage, and the delivery of online therapy sessions via Google Meet. Google LLC acts as a data processor under a Data Processing Agreement with Inner Ease Therapy. Google's privacy practices are available at policies.google.com/privacy.

Beyond the processors listed above, and Termly (which manages cookie consent, see the Cookie Policy), no other third-party platforms are used to store or process client personal or clinical data.

Personal data is not transferred outside the UK or EU without appropriate safeguards in place.

9. Confidentiality

All information shared within therapeutic sessions is treated as strictly confidential. This is a fundamental ethical principle of therapeutic practice and is taken seriously.

Confidentiality may only be broken in the following limited circumstances:

Where disclosure is required by law or court order
Where there is a serious and credible risk of harm to you or to another identifiable person
Where safeguarding concerns arise in relation to a child or vulnerable adult
As part of professional supervision: Warren Abercrombie receives regular clinical supervision as required by the HCPC, RCOT, NCPS, and National Hypnotherapy Society. Supervision is conducted confidentially. Where clinical material is discussed in supervision, it is anonymised or presented in the least identifying way possible. Supervisors are themselves bound by professional confidentiality obligations.

Where it is safe and appropriate to do so, any need to breach confidentiality will be discussed with you beforehand.

10. Sharing Your Information

Personal information is not sold, rented, or traded. Information may be shared only where necessary and only in the following circumstances:

With professional supervisors, as part of ethical practice requirements, on an anonymised basis wherever possible
With legal or regulatory authorities where required by law
With emergency services or safeguarding agencies where there is a serious risk of harm
With third-party data processors (Wix, Google Workspace) as described in Section 8, solely for the purposes of operating the service
With your GP or other healthcare professionals, only with your knowledge and consent, unless an urgent safeguarding situation requires otherwise

No information is shared with third parties for marketing, advertising, or commercial purposes.

11. Data Retention

Personal information is retained only for as long as necessary for the purpose for which it was collected, or as required by law or professional obligation.

Clinical case notes and therapeutic records are retained for a minimum of 7 years following the end of the therapeutic relationship, in line with standard UK professional therapeutic frameworks, clinical insurance requirements (Howden / Beazley), and HCPC, RCOT, and NCPS professional body guidelines.

Completed therapeutic agreements and intake forms submitted via the website are saved to the secure clinical record in Google Workspace shortly after submission, and the original submission is then permanently deleted from Wix. The clinical record in Google Workspace is the sole retained copy, subject to the retention periods above.

For clients who were under 18 at the time of treatment (should services be extended to include young people in future), records would be retained until the client's 25th birthday or for 8 years after the end of treatment, whichever is longer, in line with standard clinical practice.

Enquiry data from contact forms where no therapeutic relationship was established will be retained for no longer than 12 months from the date of last contact, after which it will be securely deleted.

At the end of the retention period, digital records are permanently deleted from Google Workspace. Any residual device-stored data is cleared.

12. Storage & Security

The following measures are in place to protect your personal information:

All clinical records are stored in a password-protected Google Workspace business account with two-factor authentication enabled
The work laptop used to create and access records is protected by full-disk encryption (BitLocker) and password authentication
Paper documents are scanned and securely shredded, no paper records are retained
Online sessions via Google Meet are not recorded without explicit advance consent
Wix Studio Plus provides encrypted form submission and enhanced GDPR-compliant data handling for website enquiries
The therapeutic agreement and intake form are collected via an encrypted Wix form on this website; submissions are permanently deleted from Wix once saved to the clinical record

While every reasonable measure is taken to protect your data, no method of electronic transmission or storage can be guaranteed to be completely secure. If you have concerns about a specific communication, please raise them directly.

13. Your Rights

Under UK data protection legislation, you have the following rights in relation to your personal information:

The right to access - you can request a copy of the personal information held about you
The right to rectification - you can ask for inaccurate information to be corrected
The right to erasure - in certain circumstances, you can ask for your information to be deleted
The right to restrict processing - you can ask for processing to be limited in certain circumstances
The right to object - you can object to certain types of processing
The right to data portability - you can request your information in a portable format in certain circumstances
The right to withdraw consent - where processing is based on consent, you can withdraw it at any time

Please note that some of these rights are subject to limitations where professional, legal, or ethical obligations apply - for example, clinical records may need to be retained for regulatory reasons even if a deletion request is made. Any such limitation will be explained clearly.

To exercise any of these rights, please contact: info@innerease.co.uk

Requests will be responded to within one calendar month in accordance with UK GDPR requirements.

14. Cookies

The Inner Ease Therapy website uses cookies to keep the site running securely and to understand basic usage patterns. Cookies are not used for advertising, marketing profiling, or tracking activity across other websites.

Full details of the cookies in use, including how to control or disable them, are set out in the Inner Ease Therapy Cookie Policy, available at www.innerease.co.uk/cookie-policy

15. Third-Party Links

The website may contain links to third-party websites, including professional body directories and resource pages. Inner Ease Therapy is not responsible for the privacy practices or content of external websites. You are encouraged to review the privacy policies of any third-party sites you visit.

16. Changes to This Policy

This Privacy Policy may be updated from time to time to reflect changes in the law, professional guidance, or the way the practice operates. The date at the top of this page will always reflect when it was last updated.

Where changes are material, clients with active therapeutic relationships will be notified directly.

17. Complaints

If you are unhappy with how your personal information has been handled, please raise this directly in the first instance:

info@innerease.co.uk | 07765 143271

If you remain dissatisfied after raising the matter directly, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Information Commissioner's Office

Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Tel: 0303 123 1113