Privacy Policy & Theraputic Agreement Reference

Privacy Policy

Last updated: 24th February 2026

This Privacy Policy explains how personal data is collected, used, stored, and protected in the course of providing psychotherapeutic counselling and social-work-informed support.

1. Data Controller

The data controller for the purposes of applicable data protection law is:

R Milnes
Practice Address: London, England N3 (details on request) and קריית מלאכי | Kiriyat Malachi, Israel
Email: ross@zerachtherapy.com

2. Professional and Legal Framework

This practice works with clients in Israel and the United Kingdom.

Where services are provided to clients located in the United Kingdom, personal data is processed in accordance with:

The UK General Data Protection Regulation (UK GDPR)
The Data Protection Act 2018

In the United Kingdom, I am registered with Social Work England as a Social Worker.
Registration Number: SW164090

In relation to my counselling, CBT, and psychotherapeutic work, I am a Senior Member of ACCPH.

I also work with clients in Israel; however, my licensing process in Israel is currently ongoing. Until that process is complete, nothing on this website should be understood as stating that I am licensed or regulated in Israel. This website will be updated once my licensing status in Israel is finalised.

3. What Information Is Collected

The following categories of personal data may be collected:

Identity information, including name, date of birth, and contact details
Health and mental health information
Assessment and session notes
Payment and invoicing information
Emergency contact details
Relevant safeguarding information
Correspondence via email or secure messaging

Sensitive personal data is processed only where relevant to the provision of services.

4. Purpose of Data Processing

Personal data is processed for the purposes of:

Providing psychotherapeutic counselling and social-work-informed support
Clinical record-keeping
Safeguarding and risk management
Professional supervision, anonymised where possible
Regulatory, professional, and insurance requirements
Invoicing and financial administration

Personal data will not be sold or used for marketing without explicit consent.

5. Legal Basis for Processing (UK Clients)

For clients located in the United Kingdom, the lawful bases for processing personal data may include:

Provision of health or social care-related services
Performance of a contract or therapeutic agreement
Compliance with legal obligations
Explicit consent, where required for special category data

Where health-related information is processed, this is done only where relevant and appropriate to the provision of services.

6. Confidentiality

All information shared in the course of therapy or support is treated as confidential, subject to the following exceptions:

Risk of serious harm to self or others
Safeguarding obligations
Legal requirement, including court order or statutory duty
Regulatory or professional investigation

Where possible, clients will be informed before any disclosure is made.

7. Data Storage and Security

Personal data is stored securely using appropriate technical and organisational measures. These may include:

Encrypted digital systems
Password-protected devices
Secure online platforms intended to support confidentiality and data security

Reasonable steps are taken to protect personal data from unauthorised access, disclosure, alteration, or loss.

8. International Data Transfers

As this practice works across Israel and the United Kingdom, personal data may be stored or processed in Israel and/or the United Kingdom, depending on the nature and location of the service provided.

Where third-party service providers are used, including secure video or communication platforms, reasonable steps are taken to ensure that appropriate safeguards are in place.

9. Data Retention

Clinical records are retained in accordance with:

Applicable legal requirements
Professional and ethical responsibilities
Insurance requirements
UK professional standards, where applicable

Retention periods will usually extend for several years after the end of services.

10. Your Rights

Where UK data protection law applies, you may have the right to:

Access your personal data
Request correction of inaccurate data
Request restriction of processing in certain circumstances
Raise concerns with the Information Commissioner’s Office (ICO)

11. Complaints

If you have concerns about how your personal data is handled, you are encouraged to raise them directly with me in the first instance.

Where relevant to services provided under my Social Work England registration, concerns may also be raised with Social Work England.

Where relevant to services provided under my ACCPH membership, concerns may also be raised with ACCPH in accordance with its complaints procedures.

Further information relating to complaints procedures in Israel will be updated once my licensing process in Israel is complete.

12. Updates

This Privacy Policy may be updated periodically. The most recent version will always appear on this website.

13. Therapeutic Agreement

Before commencing any clinical work, all clients are required to review and sign a detailed Therapeutic Agreement.

This agreement sets out:

Scope of services
Professional status and regulatory framework
Confidentiality and its limits
Data protection and privacy arrangements
Fees and cancellation policy
Safeguarding procedures
Jurisdiction and applicable law
Complaints procedure

For clients located in the United Kingdom, this agreement will also clarify which services are provided under my registration with Social Work England, and the relevant therapeutic services that fall within the scope of my ACCPH membership.

For clients located in Israel, services are offered in accordance with my current professional status, training, qualifications, and scope of practice. This website and all client documentation will be updated once the relevant licensing process in Israel is complete.

No services will commence until the Therapeutic Agreement has been reviewed and signed.