Privacy Policy

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At Tru2u, your privacy matters.

I understand that choosing to share personal information, particularly information about your health, wellbeing, and personal experiences, requires trust. This Privacy Policy explains what information I collect, why I collect it, how it is used and protected, and the choices and rights you have regarding your information.

My intention is to handle your information with care, respect and appropriate confidentiality at every stage of our work together.

Tru2u is the data controller responsible for the personal information covered by this Privacy Policy.

Tru 2 U Ltd
Contact: Audrey Lewis
Email: info@tru2u.co.uk
Website: tru2u.co.uk

If you have any questions about how your information is handled, please contact me using the details above.

The information I collect will depend on your relationship with Tru2u and the services you receive.

It may include:

• your name, date of birth and contact details;
• emergency contact information;
• information you provide about what you would like support with;
• your goals and desired outcomes;
• relevant information about your physical and emotional wellbeing;
• information about relevant health conditions, diagnoses, medication or treatment;
• information about other practitioners or healthcare professionals involved in your care, where relevant;
• information about symptoms, concerns, lifestyle or personal      circumstances that may be relevant to our work;
• information you provide during consultations and sessions;
• session notes and records relating to the work we undertake together;
• appointment, payment and administrative information;
• correspondence between you and Tru2u; and
• any other information you choose to share that is relevant to the support you receive.

I aim to collect only information that is relevant and reasonably necessary for the purpose for which it is being collected.

Some of the information you may provide about your physical or mental health and wellbeing is classed as special category personal data under UK data protection law and receives additional protection.

I may ask for this information so that I can:

• understand your circumstances and what you would like support with;
• consider whether the service I provide is appropriate for you;
• identify matters that may need to be discussed before we work together;
• tailor our work to your individual needs and goals; and
• support safe, responsible and appropriate practice.

Where I rely on your explicit consent to process health and wellbeing information, I will ask you to provide that consent clearly and separately.

You may withdraw your consent to future processing based on that consent by contacting me. Withdrawal does not affect processing that was lawful before consent was withdrawn, and there may be limited circumstances in which information must or may continue to be retained for another lawful reason. If this applies, I will explain it to you.

  I may use your personal information to:

• respond to enquiries about Tru2u services;
• arrange and manage consultations, appointments and sessions;
• assess whether the support I provide is suitable for you;
• prepare for and provide services to you;
• maintain appropriate client and session records;
• communicate with you about your appointments or our work together;
• process payments and maintain appropriate business records;
• meet professional, ethical, insurance or legal responsibilities;
• maintain the safety, security and integrity of my practice; and
• establish, exercise or defend legal claims where necessary.

Your information will not be used for unrelated purposes without an appropriate lawful basis and, where required, your knowledge or consent.

UK data protection law requires me to have a lawful basis for collecting and using personal information.

Depending upon the purpose for which information is being used, I may rely on:

Contract — where processing is necessary to take steps at your request before providing a service or to provide and administer services you have agreed to receive.

Legal obligation — where I am required to process or retain information to meet a legal requirement.

Legitimate interests — where processing is reasonably necessary for the legitimate operation and protection of Tru2u, provided those interests are not overridden by your rights and interests.

Consent — where you have been given a genuine choice and have agreed to a particular use of your information.

Where information concerning your health or wellbeing constitutes special category data, an additional condition under UK data protection law is required. Where appropriate to the circumstances of my current practice, I may rely on your explicit consent for specified uses of that information.

I will keep the lawful bases I rely upon under review as my professional practice and regulatory obligations develop.

Information you share with me will normally be treated as confidential.

As part of responsible professional practice and training, aspects of client work may sometimes be discussed with an appropriate supervisor. Where this occurs, I will limit the information shared to what is necessary and avoid identifying you wherever reasonably possible.

There are limited circumstances in which information may need to be disclosed without your consent. These may include circumstances where:

• I am required to disclose information by law;
• disclosure is necessary in connection with legal proceedings or the establishment, exercise or defence of legal rights; or
• there is a serious concern about your safety or the safety of another person and disclosure is considered necessary and appropriate.

Where it is safe, lawful and appropriate to do so, I would aim to discuss such a disclosure with you before taking action.

I do not sell your personal information.

I may share or provide access to personal information only where there is an appropriate reason to do so. This may include:

• professional supervision, subject to appropriate confidentiality;
• service providers that support the secure operation of Tru2u, including Tally, which I use to collect information submitted through online client forms, and Microsoft OneDrive, which may be used for secure electronic storage and backup of client records and working files;
• other technology, email, appointment, payment or administrative providers where necessary for the operation of Tru2u;
• healthcare or other professionals where you have agreed that information may be shared;
• professional advisers, insurers or legal representatives where reasonably necessary; and
• regulatory, legal or safeguarding bodies where disclosure is required or appropriately justified.

Where an external provider processes personal information on behalf of Tru2u, I take reasonable steps to use providers offering appropriate data-protection and security safeguards.

The providers used by Tru2u may change from time to time. Where a change materially affects how your personal information is handled, this Privacy Policy will be updated as appropriate.

Client information is intended to be stored using appropriately secured computer and/or cloud-based systems.

I take reasonable and proportionate measures to protect personal information against unauthorised access, accidental loss, misuse, alteration or disclosure. These measures may include encryption, password protection, access controls, multi-factor authentication and appropriate backup arrangements.

No method of electronic storage or transmission can be guaranteed to be completely secure, but I take the sensitivity of client information into account when selecting and managing the systems I use.

Some of the technology and service providers used by Tru2u may process or allow access to personal information outside the United Kingdom.

Where personal information is transferred outside the UK, I take reasonable steps to ensure that the transfer is made in accordance with applicable UK data-protection requirements and that appropriate safeguards are in place. Depending on the circumstances, these may include applicable adequacy regulations or approved contractual safeguards.

Further information about the safeguards applying to relevant international transfers can be requested by contacting me at info@tru2u.co.uk.

I will not keep personal information for longer than is reasonably necessary for the purpose for which it was collected, taking account of relevant professional guidance, insurance requirements and legal considerations.

For adult client records, my current intended retention period is eight years following the last professional interaction, unless there is a legitimate reason for a different retention period.

Different retention periods may apply to records relating to children or young people.

Information that does not need to form part of the client record may be retained for a shorter period.

At the end of the relevant retention period, information will be securely deleted or destroyed unless there is a lawful reason for continuing to retain it.

Retention arrangements will be reviewed periodically and may be updated to reflect changes in professional, insurance or legal requirements.

Depending on the circumstances and the lawful basis being relied upon, you may have rights in relation to your personal information, including the right to:

• ask for access to the personal information I hold about you;
• ask for inaccurate information to be corrected;
• ask for information to be deleted in certain circumstances;
• ask for the use of your information to be restricted in certain circumstances;
• object to certain types of processing;
• receive certain information in a portable format where the right to data portability applies; and
• withdraw consent where processing is based on your consent.

These rights do not apply in exactly the same way in every circumstance, and there may occasionally be a lawful reason why a particular request cannot be fulfilled in full.

If you would like to exercise one of your rights, please contact me at info@tru2u.co.uk.

I will respond in accordance with the timescales required by applicable data protection law.

Please let me know if relevant personal information changes during the time we work together.

You may also ask me to correct information that you believe is inaccurate or incomplete.

Email, messaging and other electronic communication can be convenient, but no electronic communication method is completely risk-free.

I will take reasonable care when communicating electronically and ask that you also consider the privacy of the device, email account or messaging service you choose to use when communicating sensitive information.

Where particularly sensitive information needs to be exchanged, a more secure method may be used where appropriate.

If you have a concern about the way Tru2u has handled your personal information, I would welcome the opportunity to address it with you first.

You also have the right to raise a concern with the Information Commissioner’s Office (ICO), the UK’s data protection regulator.

Information Commissioner’s Office:
Visit the Information Commissioner’s Office website

Making a complaint to Tru2u first does not affect your right to contact the ICO.

I will review this Privacy Policy periodically and update it where necessary—for example, if the services I provide, the technology I use, my professional status or applicable data-protection requirements change.

The current version will be made available through the Tru2u website and/or provided to clients as appropriate.

Where a change materially affects how existing client information is used, I will take reasonable steps to bring the change to the attention of those affected before beginning the new processing where required.

I recognise that some of the information shared during our work together may be deeply personal.

Protecting your privacy is therefore more than an administrative requirement. It is part of creating a professional, respectful and trusting environment in which you can feel comfortable being open about what matters to you.

If you are ever uncertain about why I am asking for information or how it will be used, please ask.