Privacy Policy

Last updated: February 2026

Information Governance Policy

Soul Priority operates under UK General Data Protection Regulation (UK GDPR) 2018 and the Data Protection Act 2018. We treat personal data as confidential and process it lawfully, fairly, and transparently.

We adopt the Information Commissioner’s Office (ICO) Codes of Practice and the Caldicott Principles to ensure best practice in handling personal data.

Data Controller

Soul Priority
Michelle Knowles
T: (+44) 79353 80804
E: hello@soul-priority.com
Website: soul-priority.com

What Data We Collect

We collect and process personal data to provide occupational therapy services, maintain records, and comply with professional and legal obligations.

Data includes:

Name, address, telephone number, email address
Employment and education details
Medical information (physical and mental health details relating to your condition)
Financial details (payment information)
Consultation notes and session records
Supervision notes
WhatsApp and email communications

Lawful Basis for Processing

We rely on the following lawful bases under UK GDPR Article 6:

Consent: You can withdraw consent at any time by contacting Michelle Knowles
Contract: Processing necessary to deliver services you’ve requested
Legal obligation: Compliance with HCPC registration and safeguarding requirements
Vital interests: Protecting your health, safety, or wellbeing

For sensitive health data (special category data under Article 9), we additionally rely on:

Health or social care purposes: Where processing is necessary for occupational therapy provision and care
Employment, social security, social protection law: Where required to meet statutory obligations

How We Use Your Data

We process your personal data to:

Provide occupational therapy assessment, treatment, supervision, and training services
Keep records of treatment and progress
Communicate about appointments, cancellations, and changes to services
Contact you with important information (changes to fees, working hours, holiday notices)
Comply with HCPC professional standards and safeguarding obligations
Enable communication with your GP or other healthcare professionals (with your consent)

We share your information only with:

Healthcare professionals involved in your care (with your consent)
Supervisors (where applicable, with explicit consent)
Regulatory bodies (HCPC) where required by law
Emergency services or safeguarding agencies if necessary to protect someone from harm

We do not share your data for marketing purposes. We never sell your data to third parties.

Data Storage and Security

Your records are stored on password-protected computers accessed only by Michelle Knowles. All documents containing personal data are marked “Private and Confidential.”

Where data is stored on secure third-party servers, contracts are stringently reviewed to ensure access is restricted to Soul Priority only. Third-party services we use include:

Gmail (email)
CarePatron (appointment booking and client management)

You are responsible for using secure internet connections for video consultations. The therapist cannot guarantee complete security over the internet, though reasonable steps are taken to protect confidentiality.

Data Retention

In accordance with HCPC regulations, we retain client records (including consultation notes) for 8 years after your last appointment. After this period, if we haven’t heard from you, all personal data is securely deleted from servers and devices. Printed information is destroyed using a shredder.

If data relates to ongoing enquiry, investigation, or litigation, we retain it until confirmed no longer necessary.

Anonymised testimonials provided for website use are retained indefinitely (anonymised data is not subject to UK GDPR).

You have the right to:

Be informed: Understand what personal data we hold and how we use it
Access: Request a copy of your personal data and information about how we process it
Rectification: Correct inaccurate or incomplete data
Erasure (“right to be forgotten”): Request deletion in certain circumstances
Restrict processing: Limit how your data is used in specific situations
Data portability: Receive your data in a structured format or transfer it to another organisation
Object: Oppose processing of your data in certain circumstances

To exercise these rights, contact Michelle. We respond to requests within 28 days.

Video Consultations

Video consultations use secure, encrypted platforms. However, no internet system guarantees complete security. You are responsible for:

Providing a stable internet connection
Selecting a private, quiet location for the session

We recommend using a Virtual Private Network (VPN) for added security.

Safeguarding and Disclosure

Information shared during sessions remains confidential except where:

You give explicit consent to disclose
The law requires disclosure
It is in your best interests
Disclosure is necessary to protect someone from harm (safeguarding) or prevent crime

In safeguarding situations, we share information with relevant authorities (NHS, police, local authority safeguarding services, ambulance service).

Cookies and Website Tracking

Soul Priority’s website does not use cookies, tracking technologies, or analytics tools to collect personal data about your browsing activity. We respect your privacy by providing a transparent, tracking-free experience.

Updates to This Policy

We update this policy to reflect changes in law or our practice. The most current version appears on our website. We advise you to review it regularly.

Complaints and Data Protection

If you have concerns about how we use your personal data or are dissatisfied with our response:

Michelle Knowles
E: hello@soul-priority.com
T: (+44) 79353 80804

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
www.ico.org.uk