PRIVACY POLICY
Please note that the following text is for guidance and information only regarding the systems we have in place for processing personal information at Psychology South Essex by Marta and Ellie.
The specific policy for Marta or Ellie, as appropriate, will be made available to you when you make a decision to enter a contract with either psychologist.
We are sole traders offering Clinical Psychology services. This privacy notice explains how we use any personal information we collect about you as a service user (client, patient or supervisee) or when you use our website.
For the purpose of the Data Protection Act 1988 (The Act), I, Dr Marta Karczewska and Dr Ellie Sorrell, am the data controllers for the data collected by themselves, and we are registered with the Information Commissioner's Office (reference number for Marta - A8312397; reference number for Ellie - ZA232566).
I.Introduction
1.This is a notice to inform you of our policy about all information that I record about you. It sets out the conditions under which I may process any information that I collect from you, or that you provide to us. It covers information that could identify you ("personal information") and information that could not. In the context of the law and this notice, "process" means collect, store, transfer, use or otherwise act on information.
2.I take seriously the protection of your privacy and confidentiality. I understand that all my clients are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
3.I undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
4.This policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
5.The law requires me to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. I do this now, by requesting that you read the information provided by us.
6.Except as set out below, I do not share, or sell, or disclose to a third party, any information collected about you. Under no circumstances your details are shared, sold or rented to third parties for marketing purposes.
II.What are your rights
I am committed to protecting your rights to privacy. They include:
- Right to be informed about what I do with your personal information
- Right to have a copy of all the personal information I process about you
- Right to rectification of any inaccurate factual data I process and to add to the information I hold about you if it is incomplete
- Right to be forgotten and have your personal data destroyed
- Right to restrict the processing of your personal data
- Right to object to the processing I carry out based on legitimate interest
III. Why do I collect information
1.Overview
I will collect information about you if you are a client, patient or supervise. I need to collect data and see and analyse documents containing information to carry out an assessment or to deliver psychological interventions. As a client or patient my lawful reason for processing data is that it is necessary for the provision of health or social care or treatment.
2.Categories of personal information collected
I will only use your personal data when law allows me to. The law requires that I determine under which of six defined bases I process different categories of your personal information, and to notify you of the basis for each category.
a) Fulfilling contracts: When you become my client, a contract is formed between us. The service I provide to you as a client necessarily entails you providing me with some personal information. Additionally, I may use information and data you provide for analysis, research or screening purposes for example to help me understand the performance of the services I provide. If I use the information and data for this purpose, you as an individual will not be personally identifiable.
b) Consent: Wherever possible, I aim to obtain your explicit consent to process this information. Sometimes you might give your consent implicitly, such as when you write to me requesting a response. You may withdraw your consent at any time by writing to me.
c) Legitimate interests: I may process information on the basis there is a legitimate interest, either to you or to me of doing so. Where I process your information on this basis, I do after having given careful consideration to:
- whether we could achieve the same objective by other means
- whether processing (or not processing) might cause you harm
- whether you would expect me to process your data, and whether you would, in the round, consider it reasonable to do so
For example, I may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of my business
- protecting and asserting your rights, my rights, or the rights of any other third party
- insuring against or obtaining professional advice that is required to manage business risk
- protecting your interests where I believe we have a duty to do so
d) My legal duty: Sometimes, I must process your information in order to comply with a statutory obligation. For example, I may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.
Please note: If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data. If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
IV. What information do I collect about you
I collect information about you that may be classified as sensitive or personal data, such as your name, gender (or preferred identity), address, date of birth, email address, phone numbers, GP's name and address, whether you are self-funded or funded by insurance, and the name and policy number of any insurance policy, relationships and children, occupation. I will ask for your consent to share information with your GP, and seek consent for you and I to occasionally communicate via email, for example when arranging appointments.
When you are a patient or client I record all details of your appointments and assessment/treatment so I can plan and review your treatment appropriately. In addition to personal information above. I may also collect information regarding medical conditions, prescribed medication, psychological history and current difficulties, sexuality. I may collect some of this information from your insurance company or referrer, if you have one, and some of this information will be collected directly from you.
At the end of therapy I may ask you to complete a service evaluation form that I use to evaluate and improve my clinical practice. This is anonymous. I will ask you whether you consent to sharing any comments on my website as anonymous testimonials.
I also process personal data pertaining to legitimate interests in running my business, such as invoices and receipts, accounts and tax returns.
V. How do I store your information
I take your privacy very seriously and make best efforts to ensure its security. All personal information and special category information is stored in compliance with EU General Data Protection Regulations (GDPR) rules. Hard copies of paperwork is stored in a lockable cabinet with restricted access and electronic information is stored on encrypted devices
.
VI. How long do I keep the information for
Personal data is retained as necessary for seven years in compliance with professional indemnity and legal obligations. In patients under the age of 18 years data is retained for seven years after the age of 18 years.
Administrative data is retained for up to six years as necessary in the event there are queries from HMRC. Where it is not necessary to retain the data for six years it will be destroyed as soon as possible.
VII. Who do I share your personal information with
Your information is kept confidential where possible. There are, however, some circumstances where I have a duty of care to share information. These are:
If I am asked to disclose your personal data in order to comply with any legal obligation (e.g. if I became aware of your intent to cause harm to another person/organisation (e.g. terrorise), the law may require that I inform an authority and share your personal information without seeking your permission,
In most circumstances I will not disclose personal data without consent. If I do need to share your information I will always try to ask your permission first.
Your information may be shared with outside organisations if they are directly involved in your care. For example, your GP, your insurer if they are funding your treatment. Private medical insurance companies and independent case managers sometimes expect written progress reports to authorise treatment. In this instance they will request your written permission for information to be disclosed. I will discuss with you what information is shared. The process of sharing information will always be in accordance with GDPR rules (for example, using encrypted software).
If I believe that you or others are at serious risk of harm, either from yourself or others, or if you are at risk of harming others, I will share your information with an appropriate professionals (e.g. GP, mental health service or emergency service).
If you are a supervisee I will collect sensitive data related to your psychology practice. This data may be shared with a third party if I am legally or ethically obliged to do so (e.g. if instructed by a court or if there are concerns about malpractice and need to report to a professional body).
If I am emailing a report this will be done using encrypted email software.
Clinical Psychologists are required to have regular supervision to maintain high standards, however steps will be made to protect your identity. I use first names only and do not share identifying details with my supervisor.
VIII. How do you access your information and correct it, if necessary
I try to be as open as I can in terms of giving access to their personal information. Individuals can find out if I hold any personal information by making a 'subject access request' or 'Right of Access' under the Data Protection Act and the General Data Protection Regulation. Please put your request in writing to the Data Controller. I will then supply to you;
- a description of all data we hold about you,
- inform you how it was obtained (if not supplied by you);
- inform you why, what purposes we are holding it;
- what categories of personal data is concerned;
- Inform you who it could be disclosed to;
- the retention periods of the data;
- and let you have a copy of the information in an intelligible electronic form unless otherwise requested.
IX. Complaints or queries
Psychology South Essex tries to meet the highest standards when collecting and using personal information, and take complaints seriously. Please contact me if you think our collecting or use if information is unfair, misleading or inappropriate. I would also welcome any suggestions for improving our procedures.
Our contact information is as follows:
Dr Marta Karczewska
Telephone: 075546985522
Email: marta.karczewska@psychologysouthessex.co.uk
or
Dr Ellie Sorrell
Telephone: 07754462659
Email: eleanor.sorrell@psychologysouthessex.co.uk
If you are not satisfied with the response from me, or you believe we are not processing your data in accordance with the law you have the right to raise your complaint with the Information Commissioners Office (ICO):
- Website: https::ico.org.uk
- Email: casework@ico.org.uk
- Telephone: +44 (0) 303 123 1113
X.Additional documents
This policy should be read in conjunction with the following documents, which are available upon request:
- Data retention schedule
- Subject access request procedure
- Data breach policy
- Erasure procedure
XI.Changes to my privacy policy
Any changes to my privacy policy will be posted on this websitesite (www.psychologysouthessex.co.uk.) If you are a current client when changes are made then you will be also be notified by email.
Date for review:May, 2020