Privacy Policy
Last updated July 2026 · Last reviewed: July 2026
Who we are
Formulate is operated by Formulate Tools Ltd, a company registered in England & Wales (Company No. 17065550), registered address 11 Chantry Close, Sunbury-on-Thames, TW16 7TH.
Formulate is a platform of interactive clinical psychology tools and worksheets for use by qualified and trainee mental health professionals. For data protection queries, contact formulatetools@outlook.com.
What data we collect
Therapist account data
Email address, full name, organisation name (optional), subscription status, and usage data (which worksheets accessed, when, and frequency).
Client label data
Pseudonymised client labels (initials or case codes) assigned by the therapist. The platform validates client labels to reject obvious identifiers (such as emails, phone numbers, NHS/NI numbers, dates of birth and postcodes) and warns therapists against using names. Therapists remain responsible for not entering identifiable information.
Worksheet response data
Clinical content entered by clients via homework links. This data is pseudonymous. Only the assigning therapist can view response data. Formulate does not access, review, analyse, or use response data for any purpose other than storage and display to the therapist.
Technical data
IP addresses (for security), device and browser information (for compatibility), and cookies. We set strictly necessary cookies (authentication and session) without consent. Optional analytics and advertising cookies — including the Meta Pixel and Vercel Web Analytics — are set only if you accept them. See “Cookies” below.
Legal basis for processing
Formulate plays two different roles under UK GDPR, and the legal basis depends on the role. In plain terms: for data about you (the practitioner) and your account, we are the data controller and rely on our own legal bases. For the clinical data your clients enter, you are the data controller and we act only as your processor, on your instructions.
Where we are the controller
For the following data, Formulate Tools Ltd decides how and why processing happens, so we are the controller and rely on these UK GDPR Article 6 bases:
| Data type | Legal basis | In plain terms |
|---|---|---|
| Therapist account data | Contract (Art. 6(1)(b)) | We need it to provide your account |
| Subscription and billing data | Contract (Art. 6(1)(b)) | We need it to take payment and manage your plan |
| First-party usage analytics | Legitimate interests (Art. 6(1)(f)) | Understanding how the platform is used so we can improve it |
| Optional analytics and advertising cookies | Consent (Art. 6(1)(a)) | The Meta Pixel and Vercel Web Analytics load only if you accept them via the cookie banner |
| Audit and security logs | Legal obligation (Art. 6(1)(c)) + legitimate interests (Art. 6(1)(f)) | Keeping the platform secure and able to evidence what happened |
| Support tickets and contact messages | Legitimate interests (Art. 6(1)(f)) | Responding to your enquiry |
Where we process on your behalf (you are the controller)
For clinical data about your clients, the treating clinician — not Formulate — is the data controller. We process this data only as a processor, on your documented instructions, under our Article 28 Data Processing Agreement. A processor does not hold its own Article 6 or Article 9 basis for this data; the controller's bases apply:
| Data type | Our role | The controller's legal basis |
|---|---|---|
| Client labels and case details | Processor, under the Art. 28 DPA, on the therapist's documented instructions | Contract (Art. 6(1)(b)) — the therapy agreement between clinician and client |
| Client worksheet responses and outcome scores | Processor, under the Art. 28 DPA, on the therapist's documented instructions | Contract (Art. 6(1)(b)); for health data, Art. 9(2)(h) — see “Special category data” below |
In plain terms: your clients' worksheet responses are yours, not ours. We store and display them for you, on your instructions, and never use them for any purpose of our own.
Special category data
Worksheet response data may constitute health data under Article 9. Where it does, the relevant condition is Article 9(2)(h) — processing necessary for the provision of health care, under the responsibility of a health professional. That condition belongs to the treating clinician as data controller: the processing sits under their professional responsibility, and Formulate processes the data only as their processor under our DPA. We do not process client health data for any purpose of our own.
Data sharing
We use the sub-processors listed in our Data Processing Agreement — including Supabase (database, UK), Stripe (payments), Resend (transactional email), Anthropic (AI worksheet generation, on PII-stripped input only), Vercel (hosting) and Sentry (error monitoring). With your consent, we also load analytics and advertising tools (the Meta Pixel and Vercel Web Analytics). We do NOT sell your data, share clinical response data with third parties for their own purposes, use clinical data for advertising, or train AI models on worksheet responses.
Where we store your data
Your account and clinical data are stored in the UK (Supabase, AWS eu-west-2, London). Some sub-processors operate outside the UK (see our DPA for the full list and the safeguards that cover those transfers).
Data retention
All retention rules in one place:
| Data | How long we keep it |
|---|---|
| Therapist account data | While your account is active, plus 90 days after an account deletion request, then permanently deleted |
| Client worksheet responses and outcome data | While the therapeutic relationship is active. Therapists can permanently delete client data at any time via the GDPR erasure function, and clients can request deletion via their portal; deleted data is purged after a 90-day recovery window |
| Data after subscription cancellation | On cancellation your account reverts to the free tier; existing data is retained for 90 days, then permanently deleted (see our Terms of Service) |
| Audit logs | 7 years |
| Database backups | Automated backups with point-in-time recovery are being enabled with our database platform; current status is published in our DTAC self-assessment and on the Security page |
You can export your data at any time while your account is active. If worksheet responses form part of your clinical record, export anything you need to retain before deleting it or cancelling.
Your rights
Under UK GDPR, you have the right to access, rectify, erase, restrict processing of, and port your data, and to object to processing. Contact formulatetools@outlook.com. We will respond within one month. You also have the right to lodge a complaint with the Information Commissioner's Office (ico.org.uk).
Client rights
Clients who complete homework worksheets can exercise their rights by contacting their therapist. The therapist can delete all data associated with a client using the platform's GDPR erasure function.
Cookies
Formulate uses strictly necessary cookies for authentication and session management; no consent is required for these under UK PECR. With your consent, we also use optional analytics and advertising cookies — currently the Meta Pixel (advertising-performance measurement) and Vercel Web Analytics (aggregate usage) — which may set additional cookies. We request your consent before any analytics or advertising cookies are set, and you can accept or decline them via the cookie banner displayed on your first visit.