Effective Date: 1 January 2026
This Privacy Policy explains how Marking Therapy Ltd collects, uses, and protects your personal data in compliance with the UK General Data Protection Regulation (UK GDPR) as amended by the Data (Use and Access) Act 2025, the Data Protection Act 2018, the EU GDPR, and other applicable data protection laws globally. This policy is designed to meet the standards of the professional bodies NCPS, BACP, and the Civil Mediation Council.
Please review this Privacy Policy carefully. Where we rely on your consent, for example, before processing health information, we will ask for it clearly and separately; you may withdraw it at any time.
1. Definitions
Processing: Any operation performed on personal data, such as collection, storage, or deletion.
We/Us/Our: Marking Therapy Ltd, a private limited company registered in England and Wales (Company No. 14644277), at Stanhope Road, NE33 4RB, Tyne and Wear, South Shields.
Client/You: Any individual accessing our website or services.
Website: https://www.markingtherapy.com.
2. Data Collection
We collect and process the following data:
Special Category Data: Health or sensitive data relevant to therapy or mediation, with explicit consent.
Website Interaction Data: IP address, browser type, and cookies to improve user experience.
3. How Data is Collected
Indirectly: Through cookies and analytics tools when you browse our website.
4. Legal Basis for Processing
We process your data under these legal bases:
Contractual Necessity: For service provision.
Legal Obligation: To comply with professional or statutory requirements.
Legitimate Interests: For business improvements and professional obligations.
Recognised Legitimate Interests: For specified purposes permitted under the Data (Use and Access) Act 2025, such as safeguarding vulnerable individuals or responding to emergencies.
5. Data Use
We use your data for:
Internal record-keeping and compliance with professional body standards.
Responding to enquiries and managing your account.
We do not sell or share your data with third parties for marketing purposes.
6. Sharing Data
We may share your data with:
Third-party processors (e.g., payment platforms) with appropriate safeguards.
Legal authorities if required by law.
Our clinical supervisor, for the purposes of professional supervision required by NCPS and BACP, information shared is kept to a minimum and anonymised wherever possible.
Safeguarding authorities, where we reasonably believe that you or another person (particularly a child or adult at risk) is at risk of serious harm.
Confidentiality is central to our work. We will explain the circumstances in which confidentiality may be limited at the outset of therapy or mediation, in line with the BACP Ethical Framework and the NCPS Code of Ethics. We hold Level 3 Safeguarding Adults and Level 3 Safeguarding Children certificates, and refresh this training periodically.
7. International Transfers
If data is transferred outside the UK or EEA, it will be safeguarded by appropriate mechanisms, such as Standard Contractual Clauses (SCCs) or adequacy decisions.
8. Data Security
We implement robust technical and organisational measures, including:
Multi-factor authentication for system access.
Regular security audits and employee training.
Use of secure, GDPR-compliant platforms for any online sessions or communications, following guidance issued by the Information Commissioner’s Office (ICO), as required by the NCPS Code of Ethics.
9. Data Retention
We retain personal data only as long as necessary for:
Legal or professional compliance.
Clinical records are typically retained for a minimum of six years after our last contact with you (or, for clients under 18, until they reach age 25), in line with BACP guidance and insurance requirements.
Backup copies may persist for compliance purposes.
10. Your Rights
You have the following rights under the UK GDPR:
Correction: Rectify inaccurate or incomplete data.
Erasure: Request deletion of your data (subject to legal exemptions).
Restriction: Limit processing of your data.
Portability: Transfer your data to another controller.
Objection: Object to data processing for legitimate interests.
Complaint: Complain to us directly about how we process your data. We will acknowledge your complaint within 30 days and respond without undue delay.
To exercise these rights, contact support@markingtherapy.com.
11. Cookies
Our website uses cookies for functionality, analytics, and performance. You can manage cookie preferences via your browser.
12. Third-Party Links
Our website may contain links to external sites. We are not responsible for their privacy practices.
13. Changes to this Policy
This policy may be updated periodically. Changes will be posted on this page with an updated effective date, and we will take reasonable steps to bring significant changes to your attention.
Contact Information
If you have questions or concerns about this Privacy Policy, contact us at:
Supervisory Authority
Marking Therapy Ltd is registered with the Information Commissioner’s Office as a data controller (registration reference ZB563455). You may complain to us first at support@markingtherapy.com. If you remain dissatisfied, you can contact the UK Information Commissioner’s Office (ICO) at ico.org.uk.