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Privacy Policy

Creative Solutions Therapy – www.creativesolutionstherapy.org

Last updated: 23/10/2026

1. Who we are

Creative Solutions Therapy is a dramatherapy, training and supervision service led by Dr Clive Holmwood. We are a company registered in England and Wales, company number 7846197. In this policy, “we”, “us” and “our” refer to Creative Solutions Therapy. We are the data controller for the personal information described in this policy.

Address: Village Podiatrists, Suite 2 The Lodge, Carriers Fold, Wombourne, WV5 9DH

Email: admin@creativesolutionstherapy.org · Telephone: 07908 257033

This policy explains what personal information we collect, why we collect it, how we keep it safe and the rights you have. It is written to meet the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. As HCPC-registered professionals, we also follow the Health and Care Professions Council standards on confidentiality and the British Association of Dramatherapists’ code of ethics.

2. Information we collect

We only collect the information we need. Depending on how you use our services, this may include:

  • Enquiries: your name, email address, telephone number, organisation and the content of your message when you contact us through the website, by email or by phone.
  • Therapy clients: contact details, date of birth, GP and emergency contact details, information about your health, wellbeing and circumstances, and the notes we keep about your sessions. For children and young people, this includes details of parents, carers and, where relevant, referring professionals such as social workers or schools.
  • Training and supervision: the names, job titles and contact details of the people attending or booking, attendance records and any feedback you give.
  • Billing: the name and address of the person or organisation paying, and records of invoices and payments. We do not store card details.
  • Website usage: details of how you use our website, such as the pages you visit and the type of device you use. This is collected through cookies and analytics tools, and only where you have given consent.

Please do not send detailed personal or health information through the website contact form or by email. Give us a brief outline of what you are looking for and we will arrange a time to talk.

3. How we use your information

We use your information to:

  • reply to your enquiry and arrange an initial conversation
  • assess whether dramatherapy is right for you and plan and deliver your sessions
  • keep accurate, confidential clinical records, as our professional standards require
  • communicate with parents, carers or referring professionals, where you have agreed or where the law requires
  • organise and deliver training, supervision and reflective practice sessions
  • send invoices and keep financial records
  • understand how visitors use our website so we can improve it
  • keep our services and website secure and meet our legal and professional obligations

We will never sell your personal information or use it for marketing without your clear consent.

4. Our lawful basis for using your information

Under UK data protection law we must have a lawful basis for using your personal information. The bases we rely on are:

  • Contract: to provide the therapy, training or supervision you or your organisation have arranged with us.
  • Legitimate interests: to respond to enquiries, keep business records and keep our services secure.
  • Legal obligation: to keep financial records and to act on safeguarding concerns where the law requires.
  • Consent: for analytics and other non-essential cookies, and for sharing information with others where we ask for your agreement. You can withdraw consent at any time.

Information about your health is “special category” data and has extra protection. We use it only to provide health and social care, under UK GDPR Article 9(2)(h), and it is handled under a duty of confidentiality by HCPC-registered professionals.

5. Confidentiality

What you share in therapy is confidential. We will not share it with anyone without your agreement, except where:

  • there is a serious risk of harm to you or someone else, including safeguarding concerns about a child or vulnerable adult
  • we are required to by law or by a court

Wherever it is safe and appropriate, we will talk to you first before sharing information. We also discuss our work in professional clinical supervision, as our standards require. This is done without using names or details that could identify you.

6. Who we share your information with

We only share your information when we need to, and only as much as necessary:

  • Professionals involved in your care: such as parents, carers, social workers, schools or GPs, with your agreement or where safeguarding requires.
  • Service providers: our website host (Bluehost), email provider, secure record-keeping systems and accountant. They act on our instructions and must keep your information secure.
  • Analytics: Google (Google Analytics) and Automattic (Jetpack), only where you have given consent through our cookie banner.
  • Professional and legal bodies: our insurers, regulators or legal advisers, where needed to deal with a claim or complaint, or where the law requires.

7. International transfers

Some of our service providers, including Bluehost, Google and Automattic, may store or process website and email information outside the UK, for example in the United States. Where this happens, we make sure appropriate safeguards are in place, such as the UK International Data Transfer Agreement, the UK Extension to the EU-US Data Privacy Framework or standard contractual clauses.

8. How long we keep your information

  • Enquiries that do not lead to work together are kept for up to two years after our last contact.
  • Clinical records for adults are kept for eight years after therapy ends.
  • Clinical records for children and young people are kept until their 25th birthday, or for eight years after therapy ends if that is later.
  • Training, supervision and financial records are kept for six years, to meet tax and legal requirements.
  • Website analytics data is kept for up to 14 months.

After these periods your information is securely deleted or destroyed.

9. Keeping your information secure

We take sensible steps to protect your information. Paper records are stored securely and locked away. Electronic records are password-protected and stored on secure systems. Our website uses a secure (HTTPS) connection and its software is kept up to date. Only the people who need your information to provide our services can access it.

10. Children and young people

We work with children and young people, usually following a referral or with the agreement of a parent, carer or the local authority. Children have the same data protection rights as adults. Where a child is old enough to understand their rights, usually from around 12 years old, we will involve them in decisions about their information.

11. Your rights

Under UK data protection law you have the right to:

  • ask for a copy of the personal information we hold about you
  • ask us to correct information that is wrong or incomplete
  • ask us to delete your information, where we are not required to keep it
  • ask us to restrict or stop using your information
  • object to how we use your information
  • ask for your information to be transferred to another organisation
  • withdraw your consent at any time, where we rely on consent

To use any of these rights, please email admin@creativesolutionstherapy.org. There is no charge and we will reply within one month. Some rights are limited for clinical records, for example where we must keep records for a set time, and we will explain this if it applies.

12. Cookies

Our website uses essential cookies to work properly and to remember your cookie choices. With your consent, we also use analytics cookies (Google Analytics through the MonsterInsights plugin, and Jetpack Stats) to understand how the site is used. You can change your choices at any time using the cookie settings link at the bottom of each page. Full details are in our Cookie Policy.

13. Making a complaint

If you are unhappy with how we have handled your personal information, please contact us first so we can try to put things right. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s data protection regulator:

  • Website: www.ico.org.uk
  • Telephone: 0303 123 1113

14. Links to other websites

Our website contains links to other websites, such as Community Drama, the British Association of Dramatherapists, the Health and Care Professions Council and book publishers. We are not responsible for the privacy practices of these websites, so please read their own privacy policies.

15. Changes to this policy

We may update this policy from time to time. The latest version will always be on this page, with the date it was last updated shown at the top.