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GDPR Privacy Policy
The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
I am committed to the principles set out in the General Data Protection Regulation (GDPR) (25 May 2018) and from the ICO (Information Commission Office). The GDPR is a legal framework that sets guidelines for the collection and processing of personal information of individuals within the EU. This privacy policy explains how I, Dr Tessa Crombie, comply with these laws and explains the personal or sensitive information that I collect, store and process about you as a data controller.
I, Dr Tessa Crombie, provide psychological services (including psychological assessment, therapy, supervision, and training). I am a Clinical Psychologist and approach my work with the utmost regard for a client’s wellbeing and rights. The Health and Care Professionals Council (HCPC) regulate and inform my practice.
You can find out more about my professional and legal responsibilities on their website:
Information Collected
For the purpose of providing treatment
Upon starting therapy, basic personal information will be collected for contact and identification reasons. During our therapy meetings, an assessment of your/your child’s psychological health will be completed, and notes will be taken during sessions. These will include personal and sensitive details about your life. The assessment and notes are used solely for the delivery of a therapy service to you.
Web access collection of information
I collect information when you voluntarily complete contact forms. If you complete a web-based enquiry form, I will also collect any information you provide to me. I use cookies on my website to gather information about visitors in order to monitor the quantity of website traffic. I do not identify you or any other individuals from this information.
Confidentiality
The information about confidentiality in no way contravenes you and your child’s rights under the General Data Protection Regulation May 2018 to access personal data that I hold about you. I keep confidential records and statistics about all the clients I work with. Information, but not names, will be shared with my supervisor who is also accredited and who regularly reviews my practice. These records are subject to the General Data Protection Regulation May 2018. You and your child’s personal and sensitive personal data will only be used in order to provide the service to you/your child and for managing and quality assuring the service.
Psychological therapy is a private and confidential form of help. I hold information about each of my clients and the psychological therapy they receive in confidence. This means that I will not normally give your name or any information about you to anyone outside the organisation. However, there are exceptional cases where I might ethically or legally have to give information to relevant authorities, for example if I had reason to believe that someone, especially a child or adult, is at serious risk of harm or to prevent a miscarriage of justice. I will discuss any proposed disclosure with you unless I believe that to do so could increase the level of risk to you or to someone else. There are other supervening legal and ethical obligations, such as my duty to comply with criminal investigations when I am legally obliged to do so.
Some insurance companies require reports to authorize funding / extend treatment. This may include providing a brief summary on the nature of the presenting problem and treatment work completed. Reports are sent securely in password protected documents. I will share appointment schedules with that organisation for the purposes of billing.
As a fully accredited member of the HCPC, I adhere to their ethical framework and guidelines to ensure that you receive a professional and quality service.
Your rights
I recognise that on rare occasions my clients may wish to exercise their rights under the General Data Protection Regulation May 2018 and make a subject access request in respect of their personal information held by me. You have rights relating to the information I hold to verify the accuracy or to ask for them to be supplemented, deleted, updated or corrected. You have the right to request a copy of the information that I hold about you. If at any time you wish to exercise your right under the Act you should put your request in writing to me and provide evidence of your identity, such as a copy of your passport or driver’s license and proof of your address. When I receive evidence of your identity I will respond to your request within 30 calendar days. My response to a valid subject access request will normally be in the form of a schedule listing and describing the personal data I hold on you/your child. You have a right to request the transfer of your data to another individual or company. I want to make sure that your information is accurate and up to date. You may ask me to correct or remove information you think is inaccurate. You have a right to request the transfer of your data to another individual or company.
Lawful basis for processing your information
The lawful basis for my holding and using your information is in relation to the delivery of a contract to you as a health care professional. As an accredited psychologist I operate under a strict code of confidentiality.
Data Storage
All Data is held in the United Kingdom. I do not store personal data outside the EEA. All data storage services used are fully GDPR compliant and available on request.
Data Retention
Your information is kept for the time necessary to provide the therapy service requested, however, outside of this I will hold your details and session notes for a period of 7 years following the end of treatment to comply with legal obligations that are placed upon me by my insurers. In the case of a child under 13 then records will be kept 7 years after they reach the age of 18. After this date, all data will be securely deleted.
Cancellation policy
If you intend to cancel, at least 48 hours’ notice should be given to avoid cancellation charges. If less than 48 hours notice is provided, you will be charged the full cost of your session to cover the incurred costs.
If a health or insurance company is paying for your treatment, they may make you liable for the charge. Your treatment sessions could be suspended dependant on their policy.
Reviews
We will review sessions regularly to ensure you feel you are getting the most out of therapy; you are not tied into any commitment you can end sessions at any time. If I consider your requirements beyond my competence I reserve the right to terminate our contract, this will be discussed in the session and recommendations would be provided
Consent
At the start of treatment a consent form is given to you which enables you to agree processing your personal data for the purposes outlined above.
Feedback and complaints
If you have any feedback about the service you receive from me, or you are not satisfied with your experience, please contact me. It is possible that I can resolve your complaint and I welcome feedback and if you make a complaint, I will always take it seriously as it allows me to improve the service that I can offer to others.
For further information or you wish to make a complaint please contact:
Name: Dr Tessa Crombie (Clinical Psychologist and Data Protection Representative)
Email: drtessacrombie@gmail.com
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone: +44 (0) 303 123 1113 Website: https://ico.org.uk