Privacy Notice

Privacy Notice & Data Subject Rights 

Version: 1.0 | Reviewed: April 2026 | Next Review: April 2027

 Company Name: A Different Approach Tutoring and Therapy Services Ltd

Contact: ADifferentApproach@ADAtutoringandtherapy.com

ICO Registration Number: ZC095694

At A Different Approach (ADA) Ltd, we take your privacy seriously. This notice 

explains how we collect, use, and protect the personal information you share with us 

regarding you and your child.

1. The Information We Collect

We collect data necessary to provide safe, effective, and legally compliant tutoring 

and therapy, including:

• Identity Data: Full names, dates of birth, and gender.

• Contact Data: Home addresses, email addresses, and phone numbers.

• Special Category Data: EHCP details, medical/allergy information, school 

reports, and therapeutic session notes (e.g., Drawing and Talking / STILL 

Method progress).

• Safeguarding Data: Information required to meet our statutory duties under 

KCSIE 2025/26.

2. Why We Use Your Data

• To deliver tailored tutoring and therapeutic interventions.

• To provide progress reporting to Local Authorities (e.g., Bedford Borough 

Council) or Schools.

• To comply with legal safeguarding and "Duty of Care" obligations.

• For professional billing and business administration.

3. Legal Basis for Processing

Under UK GDPR, we process data as it is necessary for the performance of a 

contract and to meet legal obligations (Safeguarding and Tax). Processing of 

"Special Category" (Health/SEND) data is conducted under the basis of providing 

health or social care.

4. Data Sharing

We only share information with third parties (Schools, Doctors, or Local Authorities) 

when we have a lawful basis to do so.

• Consent: For private commissions, we only share data with your explicit 

written consent.

• Safeguarding: We have a statutory duty to share information without consent 

if a child or adult is at risk of harm, as detailed in ADA_POL_001 

(Safeguarding & Child Protection).

• Online Safety: Our protocols for sharing digital data and social media 

boundaries are governed by ADA_POL_010 (Online Safety & Acceptable 

Use).

5. Data Security & Retention

We use AES-256 bit encrypted digital storage. To meet statutory SEND and 

insurance requirements, we adhere to the strict archive schedules outlined 

in ADA_POL_002 (Data Protection & Records Management):

• Educational & Therapy Records: Retained for 6 years after our professional 

involvement ends.

• Safeguarding Records: Retained until the student reaches age 25.

• Physical Disposal: Once these periods expire, digital data is permanently 

deleted and any physical records are disposed of via secure incineration

6. Your Rights

You have the right to request a copy of your data (Subject Access Request), ask for 

corrections, or request deletion (where legal obligations allow).

7. Contact Us

For any queries, please 

email ADifferentApproach@ADAtutoringandtherapy.com.

 If you are unhappy with our data handling, you can contact the Information Commissioner’s Office (ICO) at www.ico.org.uk