Data Protection Complaints Procedure for SMTO Member
From June 2026, therapists, practitioners and training providers need to have a clear process for handling data protection complaints. This means clients, students or course attendees must be able to raise a concern about how their personal information has been collected, used, stored, shared, retained, corrected or deleted.
This is a legal requirement and all therapists must make these documents and information available.
SMTO has provided a ready to use Data Protection Complaints Procedure and Complaint Form for members. You do not need to redesign it, but you must add your own business, clinic or practice details where indicated. You don’t have to use this form. You can make your own with your own logo.
Please watch the short explainer video first, then download the document and complete the relevant sections.
What you need to do:
Your privacy notice should be easy to find wherever you collect personal data, including your clinic, website, online booking process or client consultation paperwork.
This document is provided for guidance and member support only. Each member remains responsible for their own data protection compliance.
SMTO has updated the GDPR and data protection guidance documents for members to reflect current wording under UK GDPR and the Data Protection Act 2018.
The main updates clarify the difference between client consent and client acknowledgement. Therapists do not need to rely on consent for every part of routine clinical record keeping, such as holding contact details, consultation forms and treatment notes, where these are necessary for safe practice, professional records, insurance requirements and legal protection. Consent is still needed for optional areas such as newsletters, marketing, product ordering or sharing information with another professional where appropriate.
The updated documents also include clearer wording on health information as special category data, secure storage, retention periods, client rights, third party systems, payment providers and when information may need to be shared for insurance, legal, regulatory or professional reasons.
Members can download and adapt these templates for their own clinic use. Please make sure your privacy information is visible and available to clients, including in your clinic, on your website if you have one, and wherever clients access information or book appointments.
These templates are provided as practical guidance for SMTO members and should be adapted to suit each individual practice. Members should also check their own insurer’s requirements and use the ICO website for further guidance where needed.
MS Word Docs Below.
SMTO Master Session, Managing Complaints and Inappropriate Client Behaviour
Having a clear complaints policy is part of safe, professional and transparent clinical practice. It helps clients understand how to raise a concern, what information they need to provide, how their complaint will be reviewed, what timescales apply, and what possible outcomes may follow. It also helps therapists respond calmly and consistently, rather than trying to manage a difficult situation without a clear process.
This 47 minute SMTO Master Session provides practical guidance for therapists on managing complaints within their own clinical practice. It explores the different types of complaints that may arise, including concerns about treatment, communication, fees, appointments, boundaries or professional conduct. It also explains what a therapist should review when a complaint is received, when it may be appropriate to seek advice from their insurer, broker or professional association such as SMTO, and why a clear paper trail is essential.
The session also discusses unwanted or inappropriate client behaviour, including how to stay calm, respond directly, set clear boundaries and close the situation quickly. These moments can feel uncomfortable, but therapists should not feel they have to tolerate inappropriate language, messages or behaviour in order to remain professional.
A complaints policy template is provided alongside the recording for members to download and adapt for their own clinical practice. Therapists should update the wording to suit their business, add their business name, logo, address and contact details, and make sure the process reflects how complaints will actually be handled in their clinic.
Members are also encouraged to add a review date to their diary so the policy can be checked and updated regularly. A complaints policy should not be something that is written once and forgotten. It should remain current, accurate and easy for clients to understand.
MS Word Docs Below.
