Updated Privacy Notice for Therapy Clients (May 2018)

You may be aware of new laws relating to General Data Protection Regulation (GDPR) that are in effect from 25 May 2018.  The purpose of GDPR is to provide a set of standardised data protection laws across all EU member countries.   This document sets out how Kingston Psychology Clinic complies with these laws.

Data Control

Dr Sally Field is the data controller for Kingston Psychology Clinic.

Associate psychologists with Kingston Psychology Clinic will be additional data controllers for the clients they work with directly and may have access to more data than Dr Field due to the confidential nature of their therapy work with a specific client.  In such cases, associates will be the primary data controller for those clients.  Kingston Psychology Clinic uses an administrator who handles billing and invoicing to insurance companies and individuals using the service.  The administrator only receives basic details to allow billing and has signed a confidentiality agreement regarding your details. No sensitive clinical information is shared with the administrator.

What personal data we process

Kingston Psychology Clinic collects and processes the following personal data from therapy clients:

• Personal data: basic contact information: name, address, email, contact number, video conference ID (if online therapy), and GP contact details.
• Sensitive personal data: Signed Therapy Client Agreement, therapy records (therapist notes, letters, reports and/or outcome measures).
• If you complete a web-based enquiry form, we will also collect any information you provide to us as well as your internet protocol (IP) address.  This is automatically supplied by the website software used to offer the form.  All web services used by Kingston Psychology Clinic are verified by themselves as GDPR compliant.

If you are referred by your health insurance provider, then we will also collect and process personal data provided by that organisation. This includes basic contact information, referral information, and health insurance policy number and authorisation for psychological treatment.

The lawful basis for processing personal data

Kingston psychology clinic has a legitimate interest in using the personal data and sensitive personal data we collect to provide health treatment. It is necessary for us to provide psychological therapy to clients.

We may also ask for information on how you found our service for the purpose of our own marketing research.  No information you provide is passed on without your consent.  We will never sell your information to others.

What we do with your personal information

At Kingston Psychology Clinic we take your privacy seriously. We will only use your personal information to provide the services you have requested from us.

If you do not provide the personal information requested, then we may be unable to provide a therapy service to you.

How long we store personal information

We will only store your personal information for as long as it is required.

The sensitive personal data defined above is stored for a period of 7 years after the end of therapy. After this time, this data is deleted at the end of each calendar year.

How your personal information is used

We use the information we collect to:

• Provide our services to you.
• Process payment for such services.
• Send you information and information about our services that might be of interest to you.

Who we might share personal information with

We hold information about each of our clients and the therapy they receive in confidence. This means that we will not normally share your personal information with anyone else. However, there are exceptions to this when there may be need for liaison with other parties:

• If you are referred by your health insurance provider, or otherwise claiming through a health insurance policy to fund therapy, then we will share appointment schedules with that organisation for the purposes of billing. We may also share information with that organisation to provide treatment updates.
• In cases where treatment has been instructed by a solicitor, relevant clinical information from therapy records will be shared with legal services as required and with your written consent.

In exceptional circumstances, we might need to share personal information with relevant authorities:

• When there is need-to-know information for another health provider, such as your GP.
• When disclosure is in the public interest, to prevent a miscarriage of justice or where there is a legal duty, for example a Court Order.
• When the information concerns risk of harm to the client, or risk of harm to another adult or a child. We will discuss such a proposed disclosure with you unless we believe that to do so could increase the level of risk to you or to someone else.

What we will NOT do with your personal information

We will not share your personal information with third-parties for marketing purposes.

How we ensure the security of personal information

Personal information is minimised in phone and email communication. Sensitive personal data will be sent to clients in an email attachment that is password protected. Email applications use private (SSL) settings, which encrypts email traffic so that it cannot be read at any point between our computing devices and our mail server. Kingston Psychology Clinic will never use open or unsecure Wi-Fi networks to send any personal data.

Personal information is also stored on an office computer and on secure server owned by Kingston Psychology Clinic. These are password protected. Malware and antivirus protection is installed on all computing devices.  Mobile devices are protected with a passcode/thumbprint scanner, mobile security and antivirus software.

Your right to access the personal information we hold about you

• You have a right to access the information we hold about you.
• We will usually share this with you within 30 days of receiving a request.
• We may request further evidence from you to check your identity.
• A copy of your personal information will usually be sent to you in a permanent form (that is, a printed copy).
• You have a right to get your personal information corrected if it is inaccurate.
• You can complain to a regulator. If you think that we haven’t complied with data protection laws, you have a right to lodge a complaint with the Information Commissioner’s Office.

Kingston Psychology Clinic reserves the right to refuse a request to delete a client’s personal information where this is therapy records. Therapy records are retained for a period of 7 years in accordance with the guidelines and requirements for record keeping by The British Psychological Society (BPS; 2000)[1]and The Health and Care Professions Council (HCPC; 2017)[2].

Dr Sally Field

Chartered Clinical Psychologist & Founder of Kingston Psychology Clinic

March 2019

[1]The British Psychological Society (2000). Clinical Psychology and Case Notes: Guidance on Good Practice. Leicester: Division of Clinical Psychology, BPS.

[2]Health and Care Professions Council (2017). Confidentiality – guidance for registrants. London: HCPC.