Privacy Policy
Thank you for checking out our privacy policy. We take privacy seriously and are committed to protecting your privacy and handling your information in a responsible way while you use our website and services, this includes families, education providers, local authorities and other healthcare professionals. This policy sets out how data is collected and processed using our website and when you access our services.
We encourage you to read this policy alongside any other privacy notices we might provide, so you are fully informed about how and why we use your information.
Who’s in charge of your data?
The controller of your data is Melanie Hartgill of Thistleburrow Limited (ICO Registration Number ZA746389), and we can be contacted at letstalk@melaniehartgill.com.
Not happy with something?
We’re committed to treating your personal data with respect, transparency, and care. If you ever have questions or concerns about how your data is used, we want to hear from you, and we’ll do our best to resolve things quickly and fairly. Under the Data (Use and Access) Act 2025, you have the right to raise a complaint about how your personal data is handled. Here's how:
Step 1: Email us at letstalk@melaniehartgill.com with a brief description of your concern. You don’t need to use legal language - just tell us what’s worrying you.
Step 2: We’ll acknowledge your message and respond without undue delay, usually within 10 working days.
Step 3: If you’re not satisfied with our response, you can escalate your concern to the Information Commissioner’s Office (ICO) at www.ico.org.uk.
What type of data do we collect about you?
‘Personal data' is information that identifies you. If we've removed your identity (by making the data anonymous), it won’t be classed as personal data. We might collect, use, store, and share various types of personal data about you as follows:
Identity details such as your full name.
Contact details such as your billing address, email address, work address and telephone number.
Child details such as full name, date of birth, gender.
Education details such as school name and address, attendance record, grades, behaviour records, class information, intervention history, details regarding any special educational needs or support plans, teachers names and Special Educational Needs Coordinators (SENDCos) names, and views of the education setting.
Assessment data such as cognitive, social, emotional, sensory, physical health, language and communication assessments.
Referral information and documents from non-medical professionals such as autism outreach services, speech and language therapists, and counsellors.
Special Category Data: Includes information about your child’s health, including information about existing and previous medical health conditions, diagnosis reports, medication details, psychiatric history and any other relevant health information to enable us to carry out our services. We may also collect details about your race or ethnicity, religious or philosophical beliefs, cultural practices and genetic and biometric data) if you decide to share this with us on an online form or during any discussions with us.
Financial information such as your bank account details.
Technical information such as your internet protocol (IP address), your login data, browser type, version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access our website.
Consents for Health Data: We require your specific consent to process Special Category Data so, when you submit your details, we will ask you to confirm your consent to this processing.
How do we collect your personal data?
We use different methods to collect data from and about you. The majority of the time, our information is collected directly when you contact us in the following ways:
When you fill in any client forms (either via our website or sent directly from us to you);
Verbally during discussions;
Correspondence with us via post, phone, email or otherwise;
When you apply for our services;
When in discussion with your school, college, or other professionals with your consent;
When in receipt of reports being shared by said professionals;
When we receive information from local authorities regarding support or assessments;
When healthcare professionals share relevant medical or psychological assessments or histories;
When educational institutions provide updates on academic performance or behaviour;
When third-party service providers share data necessary for service delivery or improvement; or
When you give us feedback or contact us.
When working as a locum for Local Authorities, we access client/pupil information through secure local authority portals and systems. Following completion of assessments, we retain only the final reports in accordance with our retention policy, and all other LA-provided materials are securely deleted from our systems.
Another method we may use to collect data includes the use of automated technologies or interactions, like website cookies or other similar technologies. This includes information about your equipment, browsing actions and patterns and information about your browsing activity if you visit another website that uses the same cookies as us. This means we receive information about how you use these third-party websites.
This data collection helps us to improve user experience, and to gather information about how you use our website. For more information, please refer to our Cookie Policy, which can be accessed here.
What happens if you don’t provide us with the required data?
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our educational psychology services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
What are the purposes for which we use your personal data?
The purposes for which we will be using your data include:
To register you as a new client.
To provide our services.
To process and deliver our services, including a) to manage payments, fees and charges and b) to collect and recover money owed to us.
To manage our relationship with you e.g. to notify you about changes to our terms of this privacy policy or to ask you to leave a review.
To administer and protect our practice and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
To deliver relevant website content to you.
We rely on one or more of the following lawful conditions to process your data as outlined above:
To fulfil our contract with you;
For our legitimate interests;
To comply with legal obligations; or
Explicit consent.
In some scenarios, we will ask for your consent, especially for collecting special category data (like health data). We may process your personal data for more than one lawful reason at a time, depending on the specific purpose for which we are using your data. If you would like more information on the specific legal ground we are relying on please feel free to contact us.
Our Lawful Basis: Recognised Legitimate Interests
We sometimes process your personal data under what’s called a “recognised legitimate interest”. This is a lawful basis introduced by the Data (Use and Access) Act 2025. This means we use your data in ways that support important public or organisational aims, while respecting your rights and freedoms.
Examples include:
Helping prevent fraud or misuse of our services
Supporting safeguarding and professional standards
Responding to emergencies or protecting wellbeing
Improving accessibility and inclusion in our resources
We always carry out a balancing test to make sure our interests don’t override yours. You have the right to object to this type of processing at any time, and we’ll explain your options clearly.
If you’d like to know more or raise a concern, just email us at letstalk@melaniehartgill.com. We’re committed to transparency and respectful data use.
Use and Storage of Recordings and Photographic Materials
Any recordings (video or audio) and photographic images captured by us during the course of assessments, interventions, training, or observations shall be used exclusively for the purpose of delivering professional services, including:
Assessing pupil needs and formulating recommendations
Preparing reports or statutory advice (e.g., EHCP contributions)
Supporting staff training and reflective practice (with anonymisation where appropriate)
Informing multi-disciplinary discussions, planning, or tribunal input
All materials will be stored securely in compliance with UK GDPR standards, using encrypted systems or platforms with appropriate access restrictions. Such content will be retained only for the duration necessary to fulfil its intended purpose, typically no longer than 12 months, unless longer retention is legally required or explicitly agreed in writing.
No recordings or photographs will be disclosed, shared, or published externally without separate written parental consent, unless disclosure is required by law (e.g., safeguarding obligations). The Practice will ensure the data is handled in accordance with its internal data protection policy, and any deletion requests will be honoured where lawful and feasible.
Use of Artificial Intelligence Tools
We may use artificial intelligence (AI) tools to help us improve our administrative processes, generate resources, and support practice efficiency.
Important: We do not input any personal data, identifiable information, or confidential client details into AI tools. Any AI assistance is limited to non-identifiable tasks such as research summaries and general administrative support.
Your personal information, assessment data, and clinical records remain protected and are never processed through AI systems. If you have any questions about our use of technology, please contact us at letstalk@melaniehartgill.com.
Do we use Cookies?
Cookies help make our website work better for you, remembering your preferences and improving your experience. You can control cookie settings in your browser. Cookies make your browsing experience on our site as smooth as possible, because they remember your preferences.
Our website uses cookies to distinguish you from other users of our website. Please refer to our Cookie Policy here to learn more.
Do we use your data for marketing purposes?
No, we don’t send out any marketing information to clients.
Do we use third-party links?
Our website might link to third-party websites, tools and apps. Clicking on these links may allow third parties to collect or share your data. We do not control said websites and are not responsible for said websites’ privacy policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Do we ever share your personal data?
We take your data's security seriously and only allow certain people to access it.
For private assessments, reports are provided directly to you (the parent/guardian). We will not share your report with any third parties (including schools, other professionals, or local authorities) without your explicit written consent, except where required by law (e.g., safeguarding obligations).
Whilst providing our services, we may share you and your child’s personal and health data with the parties set out below for the purposes as stated further above.
Service providers, acting as processors who provide IT and system administration services, including (but not limitied to):
o Cloud Storage & Document Management: Microsoft SharePoint and Microsoft OneDrive for secure cloud-based storage of client records and practice documents;
o Secure Communications: Egress for encrypted email communications to ensure confidential information is transmitted securely;
o Forms & Consent Management: Jotform and Adobe for creating, managing and processing client consent forms and intake documentation;
o Psychometric Assessment Platforms: Testwise (GL Assessment), Pearson's Q Global, Hogrefe, WPS, MHS Assessment Centre, and ProEd Software for administering and scoring psychological assessments. We may share the patient's date of birth and client reference number with these platforms for assessment administration purposes;
o Financial Services: Xero for accounting and bookkeeping purposes, and our external bookkeeper and accountant who process financial data for compliance and tax purposes;
o IT Support: Freelance IT consultants who provide technical support and system maintenance under strict confidentiality obligations; and
o Administrative Support: Virtual assistants (Lennon’s Virtual Hub) who help with the day-to-day administration of our practice, including scheduling, correspondence management, and general administrative tasks.
Professional advisers including lawyers, accountants, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
As an HCPC accredited clinician, we are obliged to consult with another mental health professional for supervision purposes. This is to ensure we reflect and improve on our clinical skills. When discussing clients in supervision we only refer to clients by their first name and identifiable information is minimised.
Other professionals, such as schools, nurseries, colleges, speech and language therapists, occupational therapists, mental health practitioners, medical professionals, local authorities, social care, or early help services, where sharing is necessary and relevant for the support or assessment being provided.
Employers, such as Local Authorities, where applicable and necessary for the provision or funding of services.
HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
All the above third parties have a requirement to respect the security of your personal data. We do not permit them to use your personal data for their own purposes – they are only permitted to process your data for specified purposes in line with our instructions.
Do we ever transfer your data internationally?
We may transfer your data outside of the United Kingdom, but only when we can be sure it is protected.
Many of our external third parties are based outside the United Kingdom and so their processing of your personal data will involve a transfer of data outside the United Kingdom.
Whenever we transfer your personal data out of the United Kingdom, we make sure it is protected by at least implementing one of the following safeguards:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the United Kingdom.
Where we use certain service providers, we may use specific contracts approved by the UK Information Commissioner’s Office and the European Commission which give personal data the same protection it has in Europe.
Please contact us if you want further information on the specific process used by us when transferring your personal data out of the United Kingdom.
How secure is your data with us?
We have strong security measures in place to keep your personal information safe as outlined below. Only authorised individuals who have a need to know are granted access to your data, such as our employees or trusted partners. They will process your data in accordance with our confidentiality terms.
Client records and communications are stored using Microsoft SharePoint, which offers secure data storage, and we use Egress for encrypted email communication.
In the rare circumstances that there is a personal data breach, we have procedures in place and will notify you, along with any applicable regulator, when we’re legally required to.
Children’s Data & Age-Appropriate Design
We’re committed to protecting the privacy of children and young people who use our services or access our resources. If our website, services or content are likely to be used by children under 18, we follow the Age-Appropriate Design Code and the updated rules under the Data (Use and Access) Act 2025.
Here’s what that means in practice:
We design our services with children’s safety and understanding in mind
We avoid using unnecessary tracking or profiling tools
We explain things clearly, using child-friendly language wherever possible
We ask for parental or guardian consent when needed
We give children meaningful choices about their data
If you’re a parent, guardian, or educator and have questions about how we handle children’s data, just email us at letstalk@melaniehartgill.com.
What is our process for retaining your data?
We only keep your data as long as necessary for the reasons we collected it.
By law we have to keep medical information about patients for 7 years after treatment has finished. For any children we treat, we are obliged to retain the medical information until the child’s 25th birthday. By law we have to keep basic information about or clients (including contact, identity, financial and transaction data) for six years after they cease being patients for tax purposes.
For information that does not fall under the definition of basic, to determine the appropriate retention time, we look at what kind of data it is, how sensitive it is, the risks if it's misused, why we need it, and if there are other ways to achieve the same goals. We also consider applicable legal, regulatory, tax, accounting and other requirements.
What are your legal rights in relation to your data?
You have the following rights regarding your personal data:
Access: You have the right to ask us what personal data we hold about you and to receive a copy of that data. This is called a Subject Access Request (SAR).
We’ll respond within one calendar month, but if we need to verify your identity first, we may pause the clock while we do so. This helps protect your data and ensures we’re sharing it with the right person. If your request is complex or repetitive, we may apply proportionality rules under the Data (Use and Access) Act 2025, which allow us to limit the scope or extend the response time. We’ll always explain why and keep you informed. To make a request, just email us at letstalk@melaniehartgill.com with the subject line “DSAR Request”. You don’t need to use legal language - just let us know what you’d like to see or understand. If you’re unhappy with how we handle your request, you can raise a concern with the Information Commissioner’s Office (ICO) at www.ico.org.uk.
Correction: If the personal data we have about you is incomplete or incorrect, you can ask us to correct it.
Erasure: You can ask us to delete your personal data. It's important to note, however, that there might be legal reasons that prevent us from fulfilling this request. If such reasons exist, we will inform you when you make your request.
Objection: In certain situations, you have the right to object to the processing of your personal data.
Restriction of Processing: You can request that we restrict the processing of your personal data under specific circumstances.
Data Portability: You have the right to request the transfer of your personal data directly to you or to a third party of your choice.
Withdrawal of Consent: At any point where we rely on your consent to process your personal data, you have the right to withdraw this consent. Withdrawal of consent will not affect the legality of the processing done before the consent was withdrawn. Should you withdraw your consent, we might be unable to provide you with certain products or services. We will inform you if that is the case when you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
We won’t charge any fees for you to request access to your personal data. However, a reasonable fee may be charged if your request is clearly unjustified, repetitive or excessive. We also reserve the right to not comply in this scenario. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Changes and Contact
We regularly review our privacy policy. This policy was last updated in February 2026. Please keep us updated if your personal data changes. If you have any questions or need to exercise your rights, just get in touch.
Thanks for reading our privacy policy. If you have any questions, please do not hesitate to contact us