Introduction

The Children’s Wellness Centre (“we”, “us”, “the Centre”) is committed to protecting your privacy, safeguarding personal information, and being fully transparent about how we collect, use, store, share, and retain personal data relating to you and your child in accordance with UK GDPR, the Data Protection Act 2018, the ICO Data Sharing Code of Practice, and relevant safeguarding legislation.

This policy explains what personal data we collect, how and why we use it, our lawful bases, how information is shared, retention periods, your rights, and how to contact us.

Who We Are

Children’s Wellness Centre, 72 Grosvenor Road, Tunbridge Wells, Kent, TN1 2AS

We are registered with the Information Commissioner’s Office (ICO) under registration number ZA260752. The Centre works with independently ICO-registered Clinical Practitioners.

Joint Data Controller Relationship

To provide assessments, therapy, and related services, the Centre and each Clinical Practitioner act as Joint Data Controllers. Both parties make decisions about how personal data is used and you may exercise your rights against either the Centre or your Practitioner.

What Personal Data We Collect

We may collect:

• Personal identification data
• Special category data (health, developmental, behavioural information)
• Technical data (IP addresses, logs)
• Financial and transaction data
• Information from schools, nurseries, GPs, CAMHS, or other professionals with consent

How We Collect Personal Data

We collect data through forms, emails, phone calls, service bookings, submitted reports, information from other professionals (with consent), and website usage.

Lawful Bases for Processing (Article 6 UK GDPR)

We process personal data under:

• Performance of a contract
• Legal obligation
• Legitimate interests
• Vital interests
• Consent (used only for marketing, photos, optional external sharing)

Lawful Bases for Special Category Data (Article 9 UK GDPR)

Used for therapy, assessment, safeguarding, and explicit consent where required:

• Article 9(2)(h) – health or social care provision
• Article 9(2)(g) – substantial public interest (safeguarding)
• Article 9(2)(a) – explicit consent

How We Use Personal Data

We use data to deliver services, plan sessions, manage bookings, administer payments, communicate with you, improve services, ensure safety, and perform anonymised supervision.

Internal Information Sharing

Information may be shared with the Clinical Director, Practice Managers, Coordinators, Finance, and your Clinical Practitioner. Clinical notes are held by Practitioners; admin data by the Centre.

External Information Sharing

We share data externally:

• With your consent (schools, GPs, CAMHS, tutors, funders)
• Without consent only where lawful (safeguarding, court orders, legal obligations, risk to life)

Clinical Supervision

Practitioners share anonymised information in supervision.

Data from Schools or Other Providers

With consent, we may request information from educational or medical providers. It is securely stored and accessible to you upon request.

Retention Periods

We retain data until the child reaches age 25. Practitioners may retain clinical records per their regulatory requirements. Enquiry data is kept for up to 12 months. Financial records are kept for 7 years.

Security of Your Data

We use encrypted cloud storage, access controls, strong passwords, secure email, locked storage, and confidentiality agreements.

International Transfers

Some services may store data outside the UK/EEA. Transfers use approved safeguards such as Standard Contractual Clauses.

Your Rights

You have rights to be informed, access data, rectification, erasure, restrict processing, object, portability, withdraw consent, and complain to the ICO.

Exercising Your Rights

Contact: hello@childrenswellnesscentre.co.uk

Requests for clinical notes may also be directed to your Practitioner.

Data Breaches

Where a breach risks your rights, we will notify the ICO and affected individuals in line with legal requirements.

Cookies and Website Usage

See our Terms & Conditions for our Cookies Policy.

Photos, Videos, Testimonials, Marketing

Used only with explicit consent, which may be withdrawn at any time.

Complaints

You may complain to the ICO: https://ico.org.uk/concerns