- Who we are Circle Psychology Partners Ltd is registered with Companies House (Number 11159467). Circle Psychology Partners Ltd and its associated service, Dulwich Psychologist, deliver independent psychological therapy and counselling to children, adolescents and adults in our clinic rooms, via video calls and outside of the therapy room during behavioural experiments or in the home of our clients. Circle Psychology Partners Ltd and Dulwich Psychologist is owned and directed by Dr Christine Langhoff, Clinical Psychologist, who is registered with the Health and Care Professions Council (HCPC). Circle Psychology Partners Ltd operates two websites at www.circlepsychologypartners.co.uk and www.dulwichpsychologist.co.uk Circle Psychology Partners Ltd is committed to protecting the privacy of information provided by clients.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
- Data Control Dr Christine Langhoff is the data controller for Circle Psychology Partners Ltd and its associated service, Dulwich Psychologist. Circle Psychology Partners Ltd is registered with the Information Commissioners Office (ICO), registration reference: ZA328165, which can be searched for at: www.ico.org.uk Associate psychologists and associate counsellors taking on referrals with Circle Psychology Partners Ltd will be additional data controllers for the clients they work with directly and may have access to more data than Dr Langhoff and/or Circle Psychology Partners 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. All our associates are registered with the ICO.
- The lawful basis for processing personal data Circle Psychology Partners Ltd and Dulwich Psychologist have a legitimate interest in using the personal data and sensitive personal data we collect to provide health treatment; it is a requirement of our regulatory body, the Health and Care Professions Council. This ensures best practice care is achieved for our clients and 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 information do we collect about you? When you/your child are/is a patient or client of Circle Psychology Partners Ltd or its associated service, Dulwich Psychologist, we record all your/your child’s treatment and details of your/their appointment so that your clinician can plan your/your child’s treatment correctly. Your/your child’s health record is kept confidential within the Circle Psychology Partners Ltd at all times and is only shared with staff (including administrators and the treating clinician) when they need it to carry out their job. We collect information about you/your child that may include personal or sensitive information, such as: Personal data: basic contact information: name, address, date of birth, gender, email, contact telephone number, Skype 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). Web-based data: 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. Private Medical Insurance data: If you/your child are referred by a 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.
- What we do with your personal information At Circle Psychology Partners Ltd and Dulwich Psychologist we take your/your child’s 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. We use the information we collect to: – Provide our services to you/your child. – Process payment for such services.
- How do we store the information about you? We are committed to taking reasonable steps to protect any individual identifying information that you/your child provide/s to us. Once we receive your/your child’s data, we make best efforts to ensure its security on our systems. All personal information provided is stored in compliance with EU General Data Protection Regulations (GDPR) rules.
- How long we store personal information? We will only store your personal information for as long as it is required. Basic contact information held on a therapist’s mobile phone is deleted within 6 months of the end of therapy. The sensitive personal data defined above is stored for a period of 7 years after the end of therapy. As children gain legal capacity when they turn 18 years old, we are required to keep their notes until they are 25 or 26 years of age (The Limitation Act, 1980). After this time, this data is deleted at the end of each calendar year.
- Disclosures of your personal data We hold information about each of our clients and the therapy they receive in confidence. This means that we will not normally share your/your child’s personal information with anyone else (other than our administrators and clinicians). We may record your data including treatment notes to our clinic management software (WriteUpp). We also use Stripe, GoCardless and FreeAgent for invoicing purposes. External professional advisers (such as our accountant) may be given access to our invoicing software.
There also may be exceptions to this when there may be need for liaison with other parties: If you/your child are/is referred by a 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. If you would like us to share information about your/your child’s treatment with outside organisations that are directly involved in your/your child’s care/case, for instance, your GP or psychiatrist, or your child’s school, we will require your written consent. We will tell you with whom we would discuss your/your child’s care, and what details we would share with them. 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.
Responding to the Coronavirus advice from the Government is an obligation on all businesses in England. The development of the NHS ‘Track and Trace’ scheme is a key part of the government plan to manage Coronavirus. It may be necessary for us to share that data on request from NHS Track and Trace workers. We will do this and will play our part in making this process as effective as possible. It is likely that we will be asked to provide contact details if a case of Coronavirus or a suspected case in a member of the Circle Psychology Partners team that you have had direct contact with. There is an obligation to support the government planning. We will provide details as requested to do this. We will be sharing data on the basis that this is a Public Duty (see below) and that in the case of any health data it is necessary for the public interest, as set out. Please be assured that we will keep a record of information that we share.
NHS Test and Trace and the law: The law on protecting personally identifiable information, known as the General Data Protection Regulation (GDPR), allows Public Health England to use the personal information collected by NHS Test and Trace. The section of the GDPR that applies is: Article 6(1)(e) ‘processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller’. As information about health is a special category of personal information, a further section of the GDPR applies: Article 9(2)(i) ‘processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare’. Public Health England also has special permission from the Secretary of State for Health and Social Care to use personally identifiable information without people’s consent where this is in the public interest. This is known as ‘Section 251’ approval and includes the use of the information collected by NHS Test and Trace to help protect the public from coronavirus. The part of the law that applies here is Section 251 of the National Health Service Act 2006 and the associated Health Service (Control of Patient Information) Regulations 2002.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We 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 our instructions.
- Your Legal Rights
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 (or your child) 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.
- How you can access your information and correct it, if necessary?
Circle Psychology Partners Ltd and Dulwich Psychologist tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we 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. We will usually share this with you within 30 days of receiving a request. 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. To make a request to Circle Psychology Partners Ltd for any personal information we may hold you need to put the request in writing. We may request further evidence from you to check your identity. We want to make sure that your/your child’s personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. Please address these changes to the Data Protection Officer, via “How to contact us”.
- Complaints or queries Circle Psychology Partners Ltd and Dulwich Psychologist try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures. If you do have a complaint, contact the Data Protection Officer, Dr Langhoff, who will investigate the matter on your behalf. If you are not satisfied with the response from Circle Psychology Partners Ltd and Dulwich Psychologist, or believe we are not processing your personal data in accordance with the law you have the right to raise your complaint with the Information Commissioner’s Office (ICO) Contact information ICO: Website: https://ico.org.uk/concerns/ Email: email@example.com Telephone: +44 (0) 303 123 1113
- Changes to this privacy notice We keep our privacy notice under regular review and we will place any updates on this web page.
- How to contact us Circle Psychology Partners Ltd and its associated service, Dulwich Psychologist, is the company that you are supplying your personal information to. The Data Protection Officer for Circle Psychology Partners Ltd and Dulwich Psychologist is Dr Christine Langhoff and can be contacted by: Email: firstname.lastname@example.org Post: 175 Turney Road, Dulwich Village, London, SE21 7JU