MINDFRAME PERFORMANCE LTD – PRIVACY POLICY
Last Updated: February 2026 ICO Registration Number: ZB598160
1. INTRODUCTION
Mindframe Performance LTD is committed to protecting and respecting your privacy. This policy explains how we collect, use, and safeguard your personal data when you engage with our Sport Psychology services or use our website. We operate in strict accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
2. THE DATA WE COLLECT
We collect and process various types of data depending on your interaction with us:
- Identity Data: Name, date of birth, gender, and sport/performance level.
- Contact Data: Billing address, email address, and telephone numbers.
- Financial Data: Payment card details and bank account information processed for session fees.
- Special Category (Health) Data: Performance history, mental wellbeing notes, CBT-related thought records, and any health conditions disclosed during Sport Psychology sessions.
- Technical Data: IP address, browser type, and location data when accessing our website.
3. HOW WE COLLECT YOUR DATA
- Direct Interaction: Information you provide by filling in forms, booking consultations, or communicating via email and WhatsApp.
- Consultation Notes: Records created by our MSc-level practitioners during your 50-minute sessions.
- Automated Technologies: Technical tracking and cookies utilized through your use of the Website.
4. LAWFUL BASIS FOR PROCESSING
We process data under the following legal grounds:
- Contractual Necessity: To provide the services outlined in your Terms and Conditions.
- Legitimate Interests: For effective business management and professional supervision.
- Legal Obligation: To comply with accounting, tax, or mandatory safeguarding reporting.
- Explicit Consent: For Special Category (health) data, we rely on your explicit consent provided through your Deemed Acceptance and participation in sessions.
5. DATA SECURITY & TECHNICAL SAFEGUARDS
We have implemented appropriate security measures to prevent your personal data from being accidentally lost or accessed in an unauthorised way:
- Encryption: We use encryption technology and secure servers for all data transmitted or stored during online consultations.
- Access Control: We utilize restricted access protocols and limited personnel access, particularly for sensitive minor data.
- Digital Security: Practitioners utilize secure digital storage to protect the confidentiality of all records.
6. DATA RETENTION & MINOR PROTECTIONS
We apply rigorous retention periods to comply with professional insurance and legal standards:
- Standard Records: All client records are securely retained for 7 years from the date of the last session.
- Clients Aged 13 to 17: Records are retained until the client’s 25th birthday (7 years after reaching age 18). We apply heightened privacy protections and restricted access protocols for this group.
- Clients Under 13: In compliance with the ICO’s Children’s Code, we use advanced encryption and stricter access controls. Records are retained until the Client reaches their 25th birthday.
- Safeguarding: Access requests by parents will be evaluated to ensure they align with the best interests of the child.
7. YOUR LEGAL RIGHTS
Under the UK GDPR, you have the following rights:
- Request Access: Obtain copies of the personal data we hold about you.
- Request Correction: Rectify any inaccurate or incomplete data.
- Request Erasure: Request the deletion of data where there is no longer a legal or professional requirement for us to retain it.
- SAR Fulfillment: Subject Access Requests (SARs) will be fulfilled within one month of receipt.
8. MANDATORY DISCLOSURE & CONFIDENTIALITY
In line with BASES and HCPC codes of conduct, confidentiality is absolute except where the client’s safety, welfare, or wellbeing is at risk, or the client is a risk to others. In such events, we are obliged to report to relevant authorities.
9. CONTACT DETAILS
Mindframe Performance LTD (Company No: 14681843)
Address: Flat 11, 7 Windmill Drive, London, SW4 9DE
Email: jake@mindframeperformance.com
