Onward & Upward Psychological Consultation

PRIVACY POLICY

This policy explains what personal data will be held about you, how it is kept secure, how long it is kept for and under what circumstances information would be shared. The personal information collected is what is necessary for the progress of consultation. 

Your personal data will not be used for any other purposes other than psychological consultation.  So it will not be shared with any other person, or organisation unless you have requested this in writing or circumstances arise that make it a requirement (legally or pertaining to duty of care). 

• What information will be held about you: Personal data including your name, address, telephone number and GP practice (for emergencies only). A copy of the consultation notes will be provided to the client. 

• What is the lawful basis for holding this information: The lawful basis for holding this information is based on Legitimate Interests for the requested consultation and what it entails.

• How this information is securely stored: Personal identifying information and consultation notes are stored within secure health practice software on a password protected electronic device.

• Limits of confidentiality: The content of session discussions are confidential unless the client was to say something that suggested that they were posing a risk to themselves of others, or that someone close to them is at risk of harm. In such circumstances the consultant has a duty of care to break confidentiality and inform others such as your GP or other services as appropriate to further assess or manage risk. You would always be informed about this.

• Access to your information: You have the right to request a copy of the information held about you. If you require this information, we will require a written request and proof of identity.  All relevant information will then be provided within 28 days of the date of request. 

• How long information is kept for: In line with ICO (Information Commissioner’s Office) your personal data should not be kept any longer than is necessary to avoid increases risk of data breaches.  We will therefore only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

• To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

• By law we have to keep medical information about patients for 7 years after treatment has finished.  For any children we treat we are obliged to retain the medical information until 7 years after the child’s 18^th birthday.  By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

• In some circumstances you can ask us to delete your data: see your legal rights below for further information.

• In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

• Your legal rights - under certain circumstances, you have rights under data protection laws in relation to your personal data.  You have the right to:

          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 we hold about you and to check that we are lawfully processing it.

         Request correction of the personal data that we hold about you. This enables you to have any incomplete or    

         inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you    

         provide to us.

         Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is          

         no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal  

         data where you have successfully exercised your right to object to processing (see below), where we may have

         processed your information unlawfully or where we are required to erase your personal data to comply with local

         law. Note, however, that we 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 we are 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 we are

         processing your personal data for direct marketing purposes. In some cases, we 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 us to suspend the processing of your    

         personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

         Request the transfer of your personal data to you or to a third party. We 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 us to use or where we used the

         information to perform a contract with you.

          Withdraw consent at any time where we are 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,

        we may not be able to provide certain products or services to you. We 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 us.

        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, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.    

        Alternatively, we could refuse to comply with your request in these circumstances.

        What we may need from you - we may need to request specific information from you to help us 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. We may also contact you to

        ask you for further information in relation to your request to speed up our response.

        Time limit to respond - we try to respond to all legitimate requests within one month. Occasionally it could take us

        longer than a month if your request is particularly complex or you have made a number of requests. In this case, we

        will notify you and keep you updated.