Privacy Policy

This privacy notice explains what personal information Reframe & Regulate Ltd collects about you when you use our services, why we collect it, how it is used and stored, and what your rights are.

This policy applies to all services provided by Reframe & Regulate Ltd and to both of our websites: www.otmcalpine.co.uk and www.reframeandregulate.com.

By engaging with our services, you are deemed to have read and accepted this policy. If you have any questions, please do not hesitate to contact us using the details below.

Contact Details

What Information We Collect and Why

When you engage with our services, we may collect the following personal information, gathered by email, telephone, electronic questionnaires or forms, or in person:

• Full name and date of birth
• Contact details (telephone number, email address, home address, video call details)
• Parent or legal guardian names and contact details (where the client is a child)
• Diagnosis and presenting circumstances
• Names and contact details of other professionals involved in your or your child’s care
• Professional reports or healthcare records shared with us
• Therapy records including assessments, session notes and reports
• Correspondence between you and Rhona McAlpine
• Quotations, invoices, receipts and financial records
• Feedback provided in relation to our services

Website Usage Data

When you visit our websites, we may automatically collect certain technical information, including your IP address, browser type, device type, pages visited and time spent on the site. This data is collected via our website hosting platform and, where applicable, analytics tools such as Google Analytics. It is used solely to monitor site performance and improve user experience, and is not used to identify you personally.

Where cookies are used to collect this information, your consent will be obtained in accordance with our Cookie Policy.

Payment processing on our websites is facilitated by Stripe. Please see Stripe’s own privacy policy for details of how they handle payment data.

Lawful Bases and Your Data Protection Rights

Under UK data protection law (UK GDPR and the Data Protection Act 2018), we must have a lawful basis for collecting and using your personal information. We rely on the following lawful bases:

Your Rights

Depending on our lawful basis for processing, you have a number of rights under UK data protection law. You can find full details of these rights on the ICO’s website (ico.org.uk). A summary is set out below:

To exercise any of these rights, please contact us at otmcalpine@reframeandregulate.com. We will respond within one calendar month. There are some exemptions which may mean you do not receive all of the information you request.

Where We Get Your Information From

We collect your personal information from the following sources:

• Directly from you, by email, telephone, in person or via online forms
• From schools, educational settings or other organisations, where we have been commissioned to provide services through or alongside them
• From other healthcare professionals involved in your care, where relevant and with appropriate consent

How Long We Keep Your Information

We do not keep your personal information for longer than is necessary for the purpose for which it was collected. Specific retention periods are outlined in our Terms and Conditions.

As a general guide:

• Client therapy records are retained in line with RCOT and HCPC professional guidance, typically a minimum of eight years from the last date of contact (or until a child reaches the age of 25, whichever is longer).
• Financial records (invoices, receipts, bank transaction records) are retained for the current tax year plus six years, as required by HMRC.
• Website usage data is retained in accordance with our Cookie Policy.

Once retention periods have expired, all personal data is destroyed under confidential conditions.

For further information on retention periods, please contact us using the details above.

How We Keep Your Information Secure

We are committed to ensuring that your information is kept secure. We have in place the following arrangements to safeguard your personal data:

• Client files and therapy notes are kept in a locked filing cabinet.
• Electronic files are stored on secure, password-protected devices.
• Email communication uses standard encrypted email (Gmail). We do not use a specialist secure email system, and this is reflected in this policy. If you have concerns about email communication, please discuss an alternative with us.
• Electronic documents shared with you are password protected where appropriate.
• We will notify you and the relevant authorities of any personal data breach without undue delay, in line with our UK GDPR obligations.
• Your personal information is never used as input into artificial intelligence (AI) tools, large language models, or any automated decision-making systems. Any AI tools used by Reframe & Regulate Ltd for administrative or business purposes (such as drafting communications or general research) are used entirely separately from client data and records. Client information remains strictly confidential and is handled only by Rhona Paterson and authorised data processors as described in this policy.

Who We Share Your Information With

We will not share your personal information with third parties without your consent, except in the following circumstances:

Professional Sharing

• Where sharing is necessary for the safe and effective provision of services (for example, communication with a school where we have been commissioned to work with your child as part of a service package — this will be made explicit in our agreement with you).
• Where we are legally or professionally required to disclose information, for example in safeguarding situations, legal proceedings, or when complying with a court order.
• Where disclosure is necessary to protect someone’s vital interests.
• Where you have already made the information public.

Information Sharing and Confidentiality for School-Based Support

Financial Information

Banking transactions may be viewed by bank employees, our accountant, accounting software (Xero) and tax authorities (HMRC). When payment is made by bank transfer, your account name or reference may appear on our bank statements.

Data Processors

We use the following third-party data processors to support the running of our services:

Each processor is required to handle your data securely and in accordance with UK data protection law.

How to Access Your Information

You have the right to request a copy of the personal information we hold about you. To make a subject access request, please contact:

We will respond within one calendar month of receiving your request. Access to records may be facilitated within a session where appropriate.

How to Complain

If you have a concern about how we use your personal data, please contact us in the first instance:

• Email: otmcalpine@reframeandregulate.com
• Telephone: 07834 239317

If you remain unhappy after raising a complaint with us, you have the right to complain to the Information Commissioner’s Office (ICO):

Policy Updates

Reframe & Regulate Ltd reserves the right to update this policy. All clients will be notified of any material changes and may be asked to review and confirm acceptance of updated copies.

This policy was last reviewed in March 2026.