Your Right to Erasure
Under Article 17 of the UK General Data Protection Regulation (UK GDPR), you have the right to request the deletion or removal of your personal data where there is no compelling reason for its continued processing. This is commonly known as the "Right to be Forgotten."
When Does This Right Apply?
I must erase your personal data without undue delay if:
- The data is no longer necessary for the purposes for which it was originally collected
- You withdraw consent and there is no other legal basis for processing
- You object to processing based on legitimate interests, and there are no overriding legitimate grounds
- The data has been unlawfully processed
- The data must be erased for compliance with a legal obligation
- The data was collected in relation to information society services offered to a child
Exceptions for Therapy Practices
As a healthcare provider, there are specific circumstances where I may not be able to comply with your request for erasure:
Legal and Professional Obligations
I may need to retain your therapy records to comply with:
- Professional body requirements (BACP/UKCP ethical frameworks requiring 7-year retention)
- Legal obligations (defending against potential legal claims)
- Insurance requirements
- Statutory obligations under health and safety legislation
Public Health Interests
Processing necessary for public health purposes, including ensuring high standards of healthcare and treatment.
Archiving and Research
Processing necessary for archiving purposes in the public interest, scientific research, historical research, or statistical purposes, subject to appropriate safeguards.
How to Submit a Request
To request erasure of your personal data, please provide the following:
- Your full name and contact details
- Details of the specific data you wish to be erased
- Confirmation of your identity (photo ID may be required for security)
- The reason for your request (optional, but helpful)
- Date range of the data in question
Submit requests to:
Email: contact@paulapsychotherapist.com
Subject Line: "Right to be Forgotten Request"
Post: Paula Williams, Hubspace, Devonshire Business Centre, Letchworth, Herts SG6 1GJ
My Response Process
Upon receiving your request:
- Acknowledgment: I will acknowledge receipt within 3 working days.
- Verification: I will verify your identity to protect against fraudulent requests.
- Assessment: I will assess whether the right applies to your specific circumstances, considering my professional and legal retention obligations.
- Response: I will respond within one month (extendable to three months for complex requests) with either:
- Confirmation that your data has been erased; or
- Explanation of why I cannot comply and your right to appeal/complain.
Partial Erasure
In some cases, I may agree to erase some data while retaining other information required by law. For example:
- Erasing contact details while retaining anonymised clinical notes for research/audit
- Erasing email correspondence while retaining financial records for HMRC compliance
- Removing your name from records while retaining clinical data under a reference number for the required retention period
Third Party Notification
If I have shared your data with third parties (such as your GP with your consent), I will inform them of your erasure request where possible, unless this proves impossible or involves disproportionate effort.
Your Right to Complain
If you are dissatisfied with my response to your erasure request, you have the right to:
- Request a review of the decision
- Complain to the Information Commissioner's Office (ICO)
- Seek judicial remedy through the courts
Contact for Erasure Requests
Data Protection Contact: Paula Williams
Email: contact@paulapsychotherapist.com
Address: Hubspace, Devonshire Business Centre, Letchworth, Herts SG6 1GJ
ICO Registration: [Your ICO Number]