GDPR Policy
Privacy Policy
Claire Hogben (CH) is committed to making sure that your data is securely protected and that you are aware of the rights you hold when your data is being processed. This information includes personal information as defined in the General Data Protection Regulation (GDPR) 25 May 2018 (Data Protection Laws). See the Information Commissioners Office (ICO) for more information about data privacy and protection https://ico.org.uk/
This privacy policy is compliant with the principles of General Data Protection Regulation (GDPR). I am registered with the Information Commissioner’s Office (ICO) under the Data Protection Register, the reference number is ZB494560
CH is the Data Controller and Information Officer of her clinic, acting as a sole trader. Associate staff (psychologists and other therapists), who might take on referrals and co-working with, will be additional data controllers for the clients they work with.
This policy
By providing your personal data and/or by visiting https://www.patternspathwaystherapeuticservices.com/
you understand, accept and consent to the practices described in this policy.
Any changes made to this policy will be posted on this page. You are advised to check back frequently as, unless your consent is required, any changes will be binding on you when you continue to use the Website or work with us after the date of the relevant change.
If you have any queries relating to this policy, please contact me at infopatternandpathways@gmail.com in the first instance.
What information is collected:
I collect information which is personal and sensitive and may include: Personal information: your name, address, date of birth, registered GP, contact details (such as telephone numbers and email addresses relationships and children, occupation, video conference ID (if online therapy), GP contact details, school details (for children).
Sensitive information includes information about the difficulties you are seeking support for, medical conditions (if relevant), prescribed medication, psychological history and current difficulties, sexuality, financial information, including insurance and bank account details (if you are a private patient); contact I have had with you (appointments and notes of these sessions), a registration form, a signed therapy client agreement, letters, reports, outcome measures.
If you are being referred by a third party such as your GP, Psychiatrist or your medical insurer, they might provide information like this on your behalf.
Why Personal Data is collected:
The information is collected and maintained to comply with the law, for the purposes of contact (including responding to enquiries, communicating about appointments, offering treatment interventions and packages in line with the purpose of this service), assessing if your request for a service is appropriate to this service, providing psychological assessment, formulation, treatment, reviews and summaries of work conducted and reports within a safe and professional service. The information may also be used to work effectively with other services providing you with treatment or advice.
Personal data will also be processed with regards to legitimate business activities such as processing invoices and receipts, accounts, VAT and tax returns and in providing medical insurance companies with information for the purpose of the payment for the service.
How is the information stored?
Technological and organisational measures are used to keep your personal information safe. Personal information is stored on a computer. It is in a locked and secure location and password protected. Malware and antivirus protection is installed on all computing devices. Mobile devices are protected with a passcode/thumbprint scanner, and mobile security software. Your information may be stored on cloud storage. In the usual course of our business, third parties may be used to process and store your data on my behalf. Your data will normally be stored on secure servers in the European Economic Area (EEA).
Exceptionally, suppliers may be used who are based outside the EEA for processing and storing your data. There are strict controls over how and why your data can be accessed. By submitting your personal data, you agree to this.
Paper notes: During our initial assessment, I may ask you to complete a paper registration form and to sign a copy of our terms and conditions. Handwritten notes are usually taken during both assessment and treatment sessions, which are stored in your personal file. These notes are used to support the assessment and treatment sessions, and to create assessment and discharge reports when requested. Personal files are held in a locked filing cabinet. When you start to receive a therapeutic service from me the information you share during sessions will be recorded in session notes.
Who is information shared with?
The information that you share will be maintained in confidence, although there are exceptions to this, which includes:
Where you give your consent as you feel it would be helpful to share information with other parties that are involved in your care.
Medical insurance companies request information for the purposes of payment. This is basic details of; when sessions were attended, for what problem/diagnosis, and the type of therapy delivered. It does not cover the content of the sessions. These are completed routinely.
Insurance companies may also request information including content about summaries of your situation, presentation and progress, and your scores on questionnaires about symptoms. Such requests will be discussed with you.
I am legally and ethically obliged to share information when the reasons for sharing the information are so important that they override our obligation of confidentiality (e.g. to prevent you or someone from being seriously harmed; if there are concerns about a child’s safety or the safety of someone else).
Sometimes the service will have a legal duty to provide information about people, e.g., where personal risk is a factor and/or when a court order instructs us to do so. Records may therefore be shared without the patient's consent in exceptional situations, such as to safeguard them, other adults or children.
Who will you not share the information with?
I will not share your personal information with third parties for marketing purposes.
Considerations on Contact Information:
Personal information is minimised in phone and email communication. Your privacy is extremely important to me so please let us know if you have any specific contact instructions regarding the following:
Telephone:
If you provide a mobile phone number: I may ring, leave a message or text you, please inform me if you do not want us to do so.
If you provide a landline: I may leave a message, please inform me if you do not want me to do so.
Email:
If you provide me with your email address: I may use it to send confidential information, unless you have instructed us not to do so. To ensure e-mail correspondence is as safe as possible, please reply to an email I have sent you from infopatternsandpathways@gmail.com or clairehogbencbt@gmail.com
Please read the following before providing us with your email address:
Email Encryption:
For the purpose of sending sensitive and confidential information such as therapy reports, referrals and test results I use password protection on all documents transmitted.
Further Email Information:
Emails can be quick and convenient and will allow you to keep a record. Although due consideration has been given to the secure systems used, it may be possible to intercept your email when it is being sent over the internet. Be aware also that if you share your computer, others may read your emails.
Do not give more personal information than is needed to process your request.
Do not ask me to send you personal details that you would not want seen by other people.
I recommend any details that you send to me in an email are password protected.
If using a mobile phone – a preferred way is to use an end-to-end encryption service (such as WhatsApp).
This psychological practice does not provide an emergency service, and emails and voicemails are not immediately attended to. If you have an urgent question or feel at risk after going home after treatment, contact an emergency service e.g. 111 NHS emergency service or 999 for life threatening conditions by telephone, do NOT email infopatternsandpathways@gmail.com or clairehogbencbt@gmail.com in an emergency.
What rights do you have?
You have a right to access the information we hold about you.
Subject access requests (requests to access notes) will usually be processed within 30 days of receiving a request.
If you wish to apply for access to the information, I hold about you. Please note:
You should send your request in writing to Data Protection Officer – clairehogbencbt@gmail.com
You should provide enough information to enable us to correctly identify your records, for example include your full name, address, date of birth. Further evidence from you to check your identity might be requested.
You have a right to get your personal information corrected if it is inaccurate. If there is a difference of view, a note of your view can be put on the notes.
How do I contact the data controller:
If you have any questions or concerns about this Privacy Notice or how I process your information,
or you would like to make a complaint about a possible data breach please contact Claire Hogben.
Email: infopatternsandpathways@gmail.com or clairehogbencbt@gmail.com
If you are not satisfied with the outcome, you can contact the ICO online, (www.ico.org.uk); or by telephone (0303 123 1113). You can also write to them at: ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.