Last updated: 12 August 2026
1. WHO WE ARE
Identity Shift is the trading name of Greg Curtis, a sole trader providing counselling, psychotherapy, therapeutic life coaching, life and mind coaching and business and career coaching.
For the purposes of UK data protection law, Greg Curtis, trading as Identity Shift, is the data controller responsible for your personal information.
Our website is:
www.identity-shift.co.uk
You can contact us at:
Identity Shift
1D, Royal Oak Yard
Raikes Road
Skipton
BD23 1NP
Email: greg@identity-shift.co.uk
Telephone: 07388 002417
2. OUR COMMITMENT TO YOUR PRIVACY
Your privacy and confidentiality are important to us.
Identity Shift processes personal information in accordance with applicable UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and, where applicable, the Privacy and Electronic Communications Regulations (PECR).
Because our work includes counselling, psychotherapy and therapeutic coaching, some of the information people choose to share with us may be particularly sensitive. We take appropriate steps to protect this information and only collect and use information that is reasonably necessary for legitimate professional, contractual, legal or business purposes.
Identity Shift works only with adults aged 18 and over.
3. INFORMATION WE MAY COLLECT
Depending on how you interact with Identity Shift, we may collect:
- your name
- email address
- telephone number
- postal address where required
- information submitted through our website
- information provided when making an enquiry or arranging an appointment
- appointment and scheduling information
- information contained in emails, telephone calls, messages and other communications
- information necessary to provide counselling, psychotherapy or coaching
- intake and assessment information
- session and client records
- information you choose to provide about your circumstances, experiences, relationships, work, wellbeing, goals and personal history
- billing, invoicing and payment information
- newsletter subscription information
- reviews, feedback or testimonials you choose to provide
- technical information generated through use of our website, which may include IP address, browser, device and cookie information
We aim to collect only information reasonably necessary for the relevant purpose.
4. SPECIAL CATEGORY PERSONAL DATA
Because of the nature of counselling, psychotherapy and therapeutic coaching, information you voluntarily provide may include special category personal data.
This can include information concerning physical or mental health, racial or ethnic origin, religious or philosophical beliefs, political opinions, sexual orientation or sex life and other information protected as special category data under UK data protection law.
Special category information is given additional protection and is processed only where we have an appropriate lawful basis and an applicable condition under UK data protection legislation.
We do not sell sensitive client information or use counselling, psychotherapy or coaching records for unrelated advertising or marketing.
5. HOW WE COLLECT INFORMATION
We may collect personal information directly from you when you:
- complete our website contact form
- contact us by email or telephone
- contact us through a messaging or social-media service
- arrange a discovery call or appointment
- subscribe to our newsletter
- become a client
- provide information during or in connection with sessions
- complete intake information, exercises or other client materials
- communicate with us between sessions
- make a payment
- provide feedback, a review or testimonial
Limited technical information may also be collected automatically when you use our website through website logs, cookies and similar technologies.
Where you choose to communicate with or access Identity Shift through a third-party platform, that provider may also process information in accordance with its own privacy arrangements.
6. WHY WE USE YOUR INFORMATION
We may use personal information to:
- respond to enquiries
- arrange and manage discovery calls and appointments
- determine whether our services may be appropriate for you
- communicate with prospective and existing clients
- provide counselling, psychotherapy and coaching services
- understand your circumstances, goals and the areas you wish to work on
- prepare for and maintain continuity between sessions
- maintain appropriate professional client records
- manage our professional relationship with you
- provide agreed client materials and communications
- issue invoices and maintain financial records
- administer payments
- comply with legal, taxation, accounting, insurance and professional obligations
- manage complaints, disputes or legal claims
- protect the rights, safety and wellbeing of individuals where appropriate
- administer newsletter subscriptions
- send newsletter or marketing communications where permitted
- operate, maintain and secure our website
- understand and improve the operation of our website and services where permitted
- prevent fraud, misuse and security threats
We will not use personal information for an incompatible purpose unless permitted or required by law.
7. OUR LAWFUL BASES FOR USING PERSONAL INFORMATION
Under UK GDPR, we must have a lawful basis for processing personal information.
Depending upon the purpose, we may rely upon:
CONTRACT
Where processing is necessary to take steps at your request before entering into a contract or to provide services that you have agreed to receive.
This may include responding to requests to work together, arranging appointments, providing counselling, psychotherapy or coaching and administering the professional relationship.
LEGITIMATE INTERESTS
Where processing is necessary for the legitimate operation of Identity Shift and those interests are not overridden by your rights and interests.
Our legitimate interests may include responding to enquiries, managing client and business relationships, maintaining appropriate professional records, protecting our business and services, maintaining website and information security, improving our services and establishing, exercising or defending legal claims.
LEGAL OBLIGATION
Where processing is necessary for us to comply with a legal obligation, including applicable taxation, financial, regulatory or other statutory requirements.
CONSENT
Where you have freely provided consent for a particular purpose, such as certain marketing communications or the publication of identifiable testimonials where consent is appropriate.
Where processing is based upon consent, you can withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
VITAL INTERESTS
In exceptional circumstances, information may be processed where necessary to protect someone’s life.
Where special category personal data is processed, an additional condition permitted by UK data protection law will also apply.
8. WEBSITE ENQUIRIES
When you contact Identity Shift through the website, we may collect your name, email address, telephone number where provided and information you choose to include within your enquiry.
The information you provide may include personal or sensitive information concerning the reason you are seeking counselling, psychotherapy or coaching.
Please only provide information reasonably necessary for us to understand and respond to your enquiry.
We use this information to respond to you and, where appropriate, take steps towards arranging a discovery call or providing our services.
Providing information through the enquiry form is voluntary. However, we may be unable to respond effectively or provide the requested service without sufficient contact and enquiry information.
9. DISCOVERY CALLS AND APPOINTMENTS
Identity Shift may use third-party scheduling services to allow prospective and existing clients to arrange discovery calls and appointments.
Information required for scheduling may include your name, contact details, appointment preferences and other information you choose to provide.
Scheduling providers may process information in accordance with their own privacy arrangements.
10. CLIENT RECORDS
Where you become a client, Identity Shift may maintain records reasonably necessary to provide a safe, effective and professionally responsible service.
These may include intake information, appointment information, relevant session records, professional notes, agreed goals, client materials and communications relating to our work together.
Client records may contain highly personal or special category information and are treated confidentially and protected using appropriate security measures.
Access is restricted to those who have a legitimate reason to access the information.
11. CONFIDENTIALITY AND DISCLOSURE
Information disclosed during counselling, psychotherapy or coaching is treated confidentially.
There may be exceptional circumstances where information can or must be disclosed where this is necessary, permitted or required by law.
These may include:
- where we have a legal obligation to disclose information
- where disclosure is required by a court or other lawful authority
- where there are serious safeguarding concerns
- where there is a serious risk of harm
- where disclosure is necessary to protect vital interests
- where information is required for the establishment, exercise or defence of legal claims
Any decision to disclose confidential information will be considered carefully in accordance with applicable legal and professional responsibilities.
12. EMAIL, TELEPHONE AND ELECTRONIC COMMUNICATIONS
We may communicate with prospective and existing clients through email, telephone and electronic messaging services.
Where you choose to communicate through a third-party service or platform, that provider may process information in accordance with its own privacy arrangements.
We recommend that you avoid sending unnecessary sensitive information through ordinary electronic communications where a more appropriate method is available.
13. NEWSLETTER AND MARKETING
You may choose to subscribe to the Identity Shift newsletter.
We may collect your name, email address, subscription status and information necessary to administer your subscription.
We only send electronic marketing communications were permitted under applicable data protection and electronic communications law.
You can unsubscribe at any time by using the unsubscribe facility contained within the communication or by contacting Identity Shift.
Unsubscribing from marketing does not prevent us from contacting you where communication is necessary to respond to an enquiry, administer an appointment, provide an agreed service or meet a legal or legitimate requirement.
We do not sell subscriber information to third parties.
14. INVOICING, PAYMENTS AND FINANCIAL RECORDS
We process information necessary to administer invoices, payments and financial records.
This may include your name, contact details, details of services provided, amounts charged, payment status and other information required for legitimate financial administration.
Financial information will be retained for the periods required under applicable taxation and accounting rules.
15. REVIEWS AND TESTIMONIALS
You may choose to provide a review or feedback concerning your experience with Identity Shift.
Where Identity Shift wishes to publish an identifiable testimonial, case study or other client material directly, we will obtain appropriate permission where required.
Particular care is taken where publication could reveal that an individual has received counselling, psychotherapy or another service involving sensitive personal information.
16. WHO WE SHARE INFORMATION WITH
We do not sell or rent your personal information.
Where reasonably necessary to operate Identity Shift or provide our services, information may be processed by trusted third-party service providers.
These may include providers of:
- website hosting and technical services
- website forms and security
- email and communications
- appointment scheduling
- newsletter distribution
- invoicing, payment and financial administration
- secure digital or cloud storage
- online communication services
- IT and technical support
- professional, accounting, insurance or legal services
We may also disclose information where required or permitted by law.
Where another organisation processes personal information on our behalf, appropriate data protection arrangements are used where required.
17. INTERNATIONAL TRANSFERS
Some service providers may process or store personal information outside the United Kingdom.
Where personal information is transferred internationally, we take reasonable steps to ensure that an appropriate lawful transfer mechanism and safeguards are in place as required by UK data protection law.
These may include UK adequacy regulations or approved contractual safeguards.
You can contact us if you would like further information about the safeguards relevant to your personal information.
18. HOW LONG WE KEEP INFORMATION
We do not keep personal information for longer than is reasonably necessary for the purpose for which it was collected, taking account of professional, contractual, legal, insurance, taxation and regulatory requirements.
Client records are normally retained for six years after our work together ends, unless there is a lawful and appropriate reason to retain information for a different period.
Enquiries that do not result in an ongoing client relationship will be retained only for as long as reasonably necessary to respond to the enquiry, manage appropriate follow-up and deal with any relevant legal or business requirements.
Newsletter information will normally be retained while you remain subscribed. Where you unsubscribe, limited information may be retained where necessary to ensure that your marketing preference continues to be respected.
Financial and taxation records will be retained for the period required by applicable law and HMRC requirements.
Information connected with a complaint, dispute or legal claim may be retained for as long as reasonably necessary to deal with that matter.
When information is no longer required, it will be securely deleted, destroyed or anonymised as appropriate.
19. HOW WE PROTECT YOUR INFORMATION
Identity Shift takes appropriate technical and organisational measures to protect personal information against unauthorised access, accidental loss, inappropriate disclosure, alteration, misuse or destruction.
The measures used reflect the nature and sensitivity of the information being processed and include appropriate access controls and security measures.
Although no electronic or internet-based system can be guaranteed to be completely secure, we take reasonable steps to protect the personal information entrusted to us.
20. COOKIES AND SIMILAR TECHNOLOGIES
Our website may use cookies and similar storage or access technologies for purposes including website functionality, security, preferences, analytics and measurement.
Some technologies may be necessary for the website to operate and may fall within an applicable legal exception.
Where consent is legally required for non-essential cookies or other storage and access technologies, these should not be activated until the appropriate consent has been obtained.
Visitors should be provided with appropriate information and controls enabling them to make choices about non-essential technologies.
Further information about the cookies and similar technologies actually used by the website should be provided through the website’s cookie information and consent-management system.
21. THIRD-PARTY WEBSITES AND SERVICES
Our website may contain links to or integrate with external websites and services, including appointment booking, social media or other online services.
When you use an external service, that organisation may process information in accordance with its own privacy policy.
Identity Shift is not responsible for the privacy practices of independent third-party organisations.
22. YOUR DATA PROTECTION RIGHTS
Depending upon the circumstances and the lawful basis for processing, you may have:
- the right to be informed about how your information is used
- the right to request access to personal information held about you
- the right to request correction of inaccurate or incomplete information
- the right to request deletion of information in certain circumstances
- the right to request restriction of processing in certain circumstances
- the right to data portability where applicable
- the right to object to certain processing
- rights relating to automated decision-making where applicable
- the right to withdraw consent where processing is based upon consent
These rights are not absolute, and their application depends upon the circumstances and the lawful basis for processing.
If you wish to exercise a data protection right, contact:
greg@identity-shift.co.uk
We may need to verify your identity before fulfilling certain requests.
23. YOUR RIGHT TO OBJECT
You have the right to object to the processing of your personal information in certain circumstances.
Where personal information is processed for direct marketing, you have the right to object to that processing at any time.
Where we rely upon legitimate interests, you may also have a right to object. Any objection will be considered in accordance with applicable data protection law.
24. AUTOMATED DECISION-MAKING
Identity Shift does not use solely automated decision-making that produces legal or similarly significant effects upon individuals when determining whether or how counselling, psychotherapy or coaching services are provided.
25. COMPLAINTS
If you have concerns about how Identity Shift has handled your personal information, please contact us so that we can investigate and respond.
You also have the right to complain to the UK’s data protection regulator, the Information Commissioner’s Office (ICO).
Further information about your rights and making a complaint is available from the ICO.
26. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy where our services, technology, working practices, legal obligations or use of personal information changes.
The current version will be published on the Identity Shift website and the date at the top of this policy will be updated when appropriate.
27. CONTACT US
For questions about this Privacy Policy, your personal information or your data protection rights, contact:
Identity Shift
1D, Royal Oak Yard
Raikes Road
Skipton
BD23 1NP
Email: greg@identity-shift.co.uk
Telephone: 07388 002417
Data Controller: Greg Curtis trading as Identity Shift