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Privacy Policy & International Data Protection Notice

Last updated: July 15, 2026

This Privacy Policy describes the policies and procedures of Gabriel Marchand (Sole Practitioner) on the collection, use, storage, protection, and disposal of Your personal and sensitive information.

While My practice is based in South Africa and complies strictly with the Protection of Personal Information Act (POPIA), No. 4 of 2013, My services are offered globally. This policy is designed to respect international data protection standards, including the General Data Protection Regulation (GDPR) for clients in the EU/UK, and equivalent state/national privacy frameworks elsewhere.

By submitting any screening, application, or intake forms, and by using My Services, You explicitly consent to the cross-border transfer, collection, processing, and storage of Your information as described in this policy.

1. Definitions & Key Roles

  • The Practitioner (The "Responsible Party" or "Data Controller"): Gabriel Marchand, a sole practitioner operating online via Google Meet.

  • The Client (The "Data Subject"): Any individual applying for, screening for, or participating in My individual or group online sessions.

  • Personal Data: Any information relating to an identified or identifiable individual.

  • Special Category / Special Personal Data: Highly sensitive information, including but not limited to Your mental health history, physical health, emotional well-being, trauma history, or personal life details provided during intake/screening.

 

2. Collection of Sensitive Screening Data (Google Forms)

To evaluate your readiness and suitability for individual or group sessions, I collect sensitive, in-depth information via digital intake and screening forms (primarily hosted on Google Forms).

What We Collect

  • Identifying & Contact Information: Full name, date of birth/age, email address, phone number, physical time zone, and emergency contact details.

  • Special / Sensitive Personal Data: Deeply personal details about Your psychological history, current emotional struggles, mental health goals, trauma history, and past therapeutic experiences.

Your Consent & Cross-Border Acknowledgment

By filling out and submitting these screening forms, You explicitly acknowledge and consent to the following:

  1. Voluntary Provision: You are sharing this sensitive psychological and personal data voluntarily to assist me in screening.

  2. Cross-Border Processing: You consent to Your data being transferred to and processed in South Africa (where I am located) and globally on secure cloud-based servers (such as Google’s infrastructure).

  3. Platform Risks: While I enforce strict cybersecurity protocols, transmitting sensitive health information over third-party digital networks (such as Google) carries inherent data risks. You submit this data acknowledging these parameters.

3. Storage & Security Protocol

I enforce strict technical and organizational measures to keep your highly sensitive psychological data safe:

  • Access Control: Only Gabriel Marchand has access to raw data collected from Google Forms and Google Sheets. No virtual assistants, administrative staff, or third parties can access this data.

  • Multi-Factor Authentication (MFA): The Google Workspace account hosting My forms, client database, and calendar is protected by strict Multi-Factor Authentication (MFA) and strong, randomized passwords.

  • Device Encryption: All physical devices (laptops, tablets, mobile phones) used to access Google Workspace or conduct Google Meet sessions are fully encrypted, password-protected, and secured with biometric locks.

  • Cloud-First Storage: To reduce the risks of physical device theft, all sensitive files are kept securely in encrypted cloud environments (Google Drive) rather than downloaded onto local hard drives.

4. Data Retention & Secure Disposal Protocol

To protect Your privacy, I do not store sensitive psychological data indefinitely. I adhere to a strict lifecycle protocol for data disposal:

A. For Applicants Who Do Not Proceed

If You submit a screening form but do not join a group or begin individual sessions (either because the container is not a fit, or You choose not to move forward):

  • Retention Period: Your sensitive screening form responses and any preliminary notes will be kept for no longer than 90 days.

  • Disposal Method: After 90 days, the Google Form response, associated Google Sheet rows, and any emails related to your screening will be permanently, digitally shredded/deleted from all cloud platforms (including clearing trash/recycle bins).

B. For Active and Ongoing Clients

If You proceed with My services (individual or group):

  • Retention Period: Your intake forms, screening data, and ongoing session notes will be kept for the duration of our professional relationship, and thereafter for a period of 5 years to comply with legal, clinical, and ethical record-keeping standards in South Africa.

  • Disposal Method: Upon reaching the 5-year post-relationship threshold, all digital records, cloud folders, and associated files will be permanently deleted and purged from all servers.

5. Limitation of Liability & Third-Party Platforms

I utilise secure, industry-leading third-party platforms to run My practice (primarily Google Forms, Google Drive, and Google Meet).

While I take all reasonable security steps required by POPIA (Section 19) and global frameworks, I cannot guarantee the absolute security of Google's global servers or prevent complex cloud-level data breaches.

By using My Service and submitting sensitive screening forms, You release Gabriel Marchand from liability for any data breaches, leaks, or unauthorised access that occur due to third-party software vulnerabilities or infrastructure failures, provided I have maintained reasonable security measures (such as MFA and secure device access) on my end.

6. Your Rights Under POPIA & GDPR

Regardless of where You are located in the world, I recognise Your fundamental rights regarding Your personal data:

  • Right of Access: You may request a copy of all personal and sensitive data I hold about You at any time.

  • Right to Rectification: You may request that I update, correct, or complete any inaccurate personal details.

  • Right to Erasure ("Right to be Forgotten"): You may request that I prematurely delete and destroy your screening/session data. Please note that this is subject to overriding legal or clinical record-keeping obligations.

  • Right to Withdraw Consent: You can withdraw Your consent for me to process Your data at any time. Note that doing so during a screening phase will result in the immediate cancellation of Your application, as I cannot safely conduct sessions without screening data.

7. Contact Me

If you have any questions, concerns, or requests regarding how your sensitive screening data is handled, stored, or destroyed, please contact me directly:

Gabriel Marchand Therapy & Coaching | Relationship Recovery Process (RRP)
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