This document sets out my policy regarding information I record about you. It sets out the conditions under which I process information I collect from you, or that you provide to me. It covers information that could identify you (“personal information”). In this context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. This policy complies with UK law, including that by the EU General Data Protection Regulation (GDPR).
The Data Protection Officer is Dr Miriam Inder, Director at Better Beginnings Ltd.
1. Why do I need to collect your personal data?
I need to collect information about you so that we can:
- Know who you are so that we can communicate with you in a personal way. The legal basis for this is a legitimate interest.
- Deliver services to you. The legal basis for this is the contract with you.
- Process your payment for the services I provide. The legal basis for this is the contract with you.
- Verify your identity so that I can be sure we are dealing with right person. The legal basis for this is a legitimate interest.
- Send you relevant information (such as self-help resources). The legal basis for this is your consent.
- Provide you with a useful and relevant website. The legal basis for this is legitimate interest.
2. What information do I collect?
I collect three categories of personal information about you and (where this applies) your dependents:
- Standard personal information: this includes your name, gender (or preferred identity), address, date of birth, email address, phone numbers, the name and policy number of any health insurance policy.
- Special category data: this includes information about your mental and/or physical health, prescribed medication, psychological history, current difficulties, sexuality. I may collect some of this information from your referrer, if you have one, and some of this information will be collected directly from you. I will ask for your consent to share information with your GP, and seek consent for us to occasionally communicate via email or text, for example when arranging appointments. When you are a patient I record all details of your appointments and assessment/treatment so I can plan and review your treatment appropriately. At the end of therapy I will ask you to complete a service evaluation form that we use to evaluate and improve our clinical practice. This is anonymous. We will ask you whether you consent to sharing any comments on our website as anonymous testimonials.
I require your explicit consent for processing special category data, so when you submit your details, I will send you a further communication asking for you to confirm your consent to this processing.
- Technical Data: this includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
3. How do I use the information that I collect?
I use the data we collect from you in the following ways:
- To communicate with you so that I can inform you about your appointments with me I use your name, your contact details such as your telephone number, email address or postal address
- To create an invoice, I use your name, address and email address
- To write an assessment report, I use information relating to your current and past psychological difficulties and diagnoses.
- To provide you with written resources that you may request via my website.
- The technical data I collect is used to help run my business, provide administration and IT services, network security and to prevent fraud. It is also used to help develop my business and improve my marketing.
I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:
- Where I need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where I need to comply with a legal obligation.
Generally, I do not rely on consent as a legal basis for processing your personal data although I will get your consent when collecting special category data (such as health information).
4. How do I store your information?
All personal information and special category information is stored in compliance with EU General Data Protection Regulations (GDPR) rules and in compliance with the Data Protection Act 2018.
- Storage of Clinical records: These are kept on WriteUpp which is a secure cloud-based practice management software, which uses two-factor authentication login and encrypted data replication to keep information safe. I do not store client identifiable information on computer hard disks.
- Payment: I issue invoices using WriteUpp and Health Code, and use FreeAgent as my finance management system.
- Emails: I use an encrypted email system (ProtonMail)
- Appointment Scheduling: Initial consultations will be arranged via the mail address you provide me on the website contact form, or you may book directly with me via my online diary hosted by WriteUpp.
- Questionnaires: I use Novopsych, a GDPR compliant routine outcome measurement platform. I allocate you an ID number to protect your identity. No patient identifiable information is stored in Novopsych.
5. How long do I keep the information?
The Data Protection Act 2018 states that personal data processed for any purpose or purposes should not be kept for longer than is necessary for that purpose all those purposes. This means I will not store or keep personal data for longer than is necessary or required by law. Personal data will need to be retained for longer in some cases than in others. A decision in how long personal data will be retained will be based on individual needs. A judgement will be made about:
- the current and future value of the information;
- the costs, risks and liabilities associated with retaining the information;
- and the ease or difficulty of making sure it remains accurate and up to date.
The minimum recommended period for retention of adult mental health personal data is seven years.
If you contact me with an initial enquiry and share personal details, but do not then become a client, I will delete your personal information after four weeks. If you conform you do not want to pursue a service within those four weeks I will destroy the information immediately.
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 it will be destroyed as soon as possible.
6. Who do I share information with?
Your information is kept confidential where possible. There are, however, some circumstances where I have a duty of care to share information (for example safeguarding concerns), or where I have to share your personal information by law (to help law-enforcement agencies perform their duties). In most circumstances I will not disclose personal data without your consent.
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 transmitting information will always be in accordance with GDPR rules (for example, using encrypted email software).
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).
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 our supervisors.
Your data may also be shared with the following:
- Services providers, acting as processors who provide IT and system administration services.
- Professional advisers, acting as processors or joint controllers, including healthcare professionals, lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities, acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with my instructions.
Many of my external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever I transfer your personal data out of the UK, I ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Where I use certain service providers, I may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact me if you want further information on the specific mechanism used by me when transferring your personal data out of the UK.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
The site uses the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of the website. They include, for example, cookies that enable you to log into secure areas of our website, such as to make an appointment.
- Analytical or performance cookies. These allow me to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps me to improve the way the website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to the website. This enables me to personalise our content for you, greet you by name and remember your preferences.
You can find more information about the individual cookies used and the purposes for which they are used in the table below:
|Cookie Title Cookie Name||Purpose|
|__cfduid||The cookie is used by cdn services like CloudFare to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It does not correspond to any user ID in the web application and does not store any personally identifiable information|
|cookielawinfo-checkbox-non-necessary||This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Non-necessary”.|
|cookielawinfo-checkbox-necessary||This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Necessary”.|
|_ga||This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site’s analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.|
|_gid||This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visited in an anonymous form.|
|isNoticeHidden||This cookie is set when the user chooses to close the notice at the top of the website. The cookie is used to store the user choice and hide the notice throughout the website.|
We do not share the information collected by the cookies with any third parties.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website. Except for essential cookies, all cookies will expire after two years.
8. Data Security
I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, I limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on my instructions and they are subject to a duty of confidentiality.
I have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where I am legally required to do so.
9. Your Rights
You have the following rights (certain exceptions apply):
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data I hold about you and to check that I am lawfully processing it.
Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to me.
Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where I am relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios:
If you want me to establish the data’s accuracy.
Where my use of the data is unlawful but you do not want me to erase it.
Where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for me to use or where I have used the information to perform a contract with you.
Withdraw consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain products or services to you. I will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact me.
No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I could refuse to comply with your request in these circumstances.
What we may need from you. I may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up my response.
Time Limit to respond. I try to respond to all legitimate requests within one month. Occasionally it could take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.
10. Complaints and Contact Details
I always try to meet the highest standards when collecting and using personal information, and take complaints seriously. Please contact me if you think my collecting or use of information is unfair, misleading or inappropriate. I would also welcome any suggestions for improving procedures.
Telephone: 01245 905676
You also have the right to raise your complaint with the Information Commissioners Office (ICO):
Website: https: ico.org.uk
Telephone: +44 (0) 303 123 1113
If you are a current client when changes are made then you will be also be notified by email.
Version 2, February 2021