Privacy Policy

Two Golden Words – Privacy Policy

Last updated: 1/2/2026

This Privacy Policy explains how I collect, use, store, and protect personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

I am committed to protecting your privacy and handling your information with care, professionalism, and transparency.

1. Who I Am

This service is provided by:

  • Name: Nina Goldfuss
  • Practice Name: Two Golden Words
  • Business Structure: Sole Trader
  • Website: https://www.twogoldenwords.com
  • Email: nina@twogoldenwords.com

I am the Data Controller for all personal data collected.

2. Information I Collect

I may collect the following:

Personal Information

  • Parent/carer name
  • Child's name and date of birth
  • Email address
  • Address (if required)

Health & Therapy Information (Special Category Data)

  • Developmental and medical history
  • Assessment results
  • Therapy notes and reports
  • Videos, recordings, and observations
  • Education and SEN information

Technical Information

  • Booking data via Cal.com
  • Zoom session data
  • Website usage data (if applicable)

Payment Information

  • Billing records via Stripe
  • (Card details are never stored by me)

3. How I Collect Data

I collect information when you:

  • Book sessions
  • Complete forms
  • Attend sessions
  • Share documents/videos
  • Contact me by email
  • Use my website

4. Lawful Basis for Processing

I process your data under the following lawful bases:

  • Contract – to deliver therapy services
  • Legal Obligation – professional record keeping
  • Legitimate Interests – service management
  • Explicit Consent – for health data and recordings

You may withdraw consent at any time where applicable.

5. How I Use Your Data

Your data is used to:

  • Deliver assessments and therapy
  • Monitor progress
  • Write reports
  • Communicate with you
  • Manage bookings and payments
  • Meet professional standards
  • Improve services

I do not sell or misuse your data.

6. AI-Assisted Transcription (Optional)

For some sessions (particularly assessments), live transcription and AI-supported note-taking tools may be used to support accuracy and clinical documentation. These tools are used securely and only for professional purposes.

You have the right to opt out of AI-assisted transcription at any time. Please inform me before your session if you do not wish this to be used.

7. Data Storage & Security

Client data is stored securely using:

  • Smilenotes clinical system
  • Encrypted devices
  • Password-protected accounts
  • Secure Zoom sessions

Only I have access to your records.

8. Data Retention

Records are kept in line with professional guidance:

  • Children's records: Until age 25
  • Adult records: 8 years
  • Financial records: 6 years
  • Enquiries: 12 months

After this, data is securely deleted.

9. Sharing Information

Information is shared only when necessary:

  • With your consent (schools, GPs, professionals)
  • With Stripe, Cal.com, Zoom, Smilenotes
  • If legally required

All third parties are GDPR compliant.

10. International Transfers

Some providers may store data outside the UK. Safeguards are in place through GDPR-compliant agreements.

11. Your Rights

You have the right to:

  • Access your data
  • Correct inaccuracies
  • Request deletion (where applicable)
  • Restrict processing
  • Object
  • Withdraw consent

Contact: nina@twogoldenwords.com

12. Children's Data

Parental consent is required for children under 16. Only necessary information is collected.

13. Complaints

If you are unhappy, please contact me first and I will do my best to resolve the problem.

You may also contact the Information Commissioner's Office (ICO):

Information Commissioner's Office (ICO)

www.ico.org.uk

0303 123 1113

14. Updates

This policy may be updated. The latest version will be published on my website.