Important Information for Subscribers

Important Information for Subscribers

  • Where We (Desuto Ltd) process any personal data on Your behalf, when performing Our obligations under the Terms of Service, You shall be the data controller and We shall be a data processor.
  • You shall own all right, title and interest in and to all of the Subject Data and shall have sole responsibility for the legality, reliability, integrity, accuracy and quality of the Subject Data.
  • Desuto will provide record templates but there is no requirement for users to complete template fields. The system will store the data that is collected by the customer, its employees and /or contractors in whatever form they choose. Desuto does not determine the type or category of data that is collected. Decisions about the type and category of data and the level of detail are the responsibility of the customer, its employees and contractors.
  • Desuto will store the data according to the time schedule determined by the customer. The length of storage and deletion of data is determined by the customer.
  • Desuto Ltd will meet its Data processor obligations as required in this agreement and in law.


  • Under the Data Protection (Charges and Information) Regulations 2018, individuals and organisations that process personal data need to pay a data protection fee to the Information Commissioner’s Office (ICO), unless they are exempt.
  • This applies to the use of TherapyRecord.Online

(This is also true if you keep any kind of electronic record of your clients data including word processed documents or letters, client email addresses, client contact details in a mobile phone, client names on an online schedule, digital audio or video recording for supervision or training)

  • You will need to provide us with the name of the individual responsible for data protection or in the case of organisations, the Data Protection Officer.

Lawful basis and Consent

  • You must ensure that You are entitled to transfer the relevant personal data to TherapyRecord.Online so that We may lawfully use, process and transfer such personal data in accordance with this Agreement on Your behalf.
  • You must ensure that the relevant third parties have been informed of, and have given their consent to, such use, processing, and transfer as required by the Data Protection Legislation.
  • You can view a sample ‘How we use your data’ and a sample data subject ‘Consent form’ here.
  • It is Your responsibility to ensure that your consent form is suitable for Your service and your purposes.
  • It is Your responsibility to ensure that the consent form is signed by each client and uploaded onto the system.