Contact Details

Dr Jyoti Pooni, Clinical Psychologist

GROW – The Psychology Clinic

+44 7842 243557

admin@grow-thepsychologyclinic.com

www.grow-thepsychologyclinic.com

Introduction

This privacy policy provides details of how your personal data is collected and processed when you use GROW – The Psychology Clinic. GROW takes the privacy rights of all its clients seriously and adopts a high standard of compliance and confidentiality when dealing with your data. GROW wants you to feel that a safe place has been created for you to discuss your concerns and feelings in a highly confidential environment.

Data Controller

Dr Jyoti Pooni of GROW – The Psychology Clinic is the data controller and is responsible for your personal data.

Why do I collect personal information about you?

I collect information about you to support the provision of a safe and professional service and in order to provide you with an individualised psychological assessment and treatment plan. It is therefore in my legitimate interest as a Clinical Psychologist to collect your personal data. You do not have to agree to share information with me. However, in many cases I may not be able to offer you a service if you do not. The information I collect about you will be used to offer you the best possible service and to comply with legal requirements. It will not be shared with third parties unless there is a legal requirement to do so or it is in your best interests.

What personal information do I collect?

Most of the personal information I process is provided to me directly by you. I currently collect and process the following information:

• Personal Data includes your name, date of birth, gender and GP details.
• Contact Data includes your postal address, your email address and your telephone numbers
• Sensitive Data includes information about your health and the difficulties you are seeking help for. Other information such as previous and current health conditions, psychiatric history and any other relevant health information to enable me to carry out my services to you may also be requested.
• Financial Data includes bank and payment card details and details about payments to and from you.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

All of the above information along with information you share during sessions will be recorded electronically and kept in your personal client records.

It is important that the personal data I collect about you is accurate and up to date. Please inform me of any changes to your personal data during your relationship with GROW – The Psychology Clinic.

How I use your personal information

I use the information collected in accordance with all laws concerning the protection of personal data, including the Data Protection Act 1998 and the GDPR 2016. I use the personal information you provide to:

• Respond to your enquiry and register you as a new client
• Communicate with you about appointments
• Offer you high quality therapeutic assessment and treatment plans
• To create invoices and keep accurate payment / accounting records
• To comply with the law

As part of providing our service to you it may be helpful to communicate via e-mail or messages, for example if you need to arrange or change an appointment. To ensure e-mail correspondence is as safe as possible, please email the following address only admin@grow-thepsychologyclinic.com. When communicating via mobile phone, I prefer to use an end-to-end encrypted messaging service (such as WhatsApp). If you are not able to use such a service I may use SMS (text messages). If you prefer not to communicate via e-mail or text, please let me know.

When will I share your personal information?

Information you share remains confidential within certain boundaries. This means that I will only share information with other parties if I become concerned that you, your child, or others (where relevant), are at risk of harm. I am legally and ethically obliged to share information in the following situations:

• If there are concerns about your child’s safety or the safety of someone else, I will need to share information with the relevant agencies such as your GP or social care. I will always aim to discuss this with you first unless in an emergency situation such as the child being in immediate danger.
• If asked by a solicitor for copies of any of your documentation, I will discuss with you what is helpful to share but may be legally obliged to share some information.

If you feel it would be helpful for me to share reports or treatment summaries with other health care professionals involved in your care then I am able to do this with your consent.

How I store the information I collect about you

Your personal information is stored securely on ISO27001 certified (an international standard to manage information governance and security) practice management software called Writeupp. It uses two-factor authentication login and encrypted data replication across different servers to keep your records safe. All electronic devices such as mobile phones/laptops/tablets that are used to access such data use encryption.

Amongst other things, practice management software and secure google cloud is used for online bookings, email and SMS reminders, video consultation and electronic record keeping including individual client health records and session note keeping.

Grow also assigns a unique ID to each clients health record (WUID), similar to a NHS number. This ID can be used when sending emails and text SMS to ensure that no patient identifiable information is used. Your contact details will be stored using this WUID on my work mobile to identify your telephone number, in case I need to contact you.

Any confidential information containing sensitive data or information sent by Dr Jyoti Pooni via the Internet will be encrypted and/or password protected (password sent separately by text). Letters sent to professionals such as GPs, by surface mail, will be clearly marked Confidential. All electronic devices (e.g. computer, laptop and phone) used to access stored information will themselves be password protected.

None of your personal information will be stored on my website.

How long will I use your data for?

Every effort will be made to keep your personal information accurate, complete, and up to date. If any of your information changes please let me know so that I can update our records.

The Data Protection Act (1988) states that personal data processed for a purpose or purposes shall not be kept for longer than is necessary for that purpose or purposes. This means that I will not keep personal data for longer than is necessary or required by law. Your records will be kept for 7 years after the conclusion of our contract, in line with the British Psychological Society guidance. When I destroy records I delete any files.

Your Data Protection 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 the information stored about you. I may require additional verification of your identity in order to process this request. I will also consider whether providing the personal information requested may violate your vital interests and have the right to, where absolutely necessary, withhold such personal information to the extent permitted by law.

Right to rectify any inaccurate or incomplete personal information that I hold about you though I may need to verify the accuracy of the new data you provide to me.

Request erasure of your personal information to delete or remove personal data where there is no good reason for me continuing to process it or when our processing no longer has a lawful basis. In some cases I would discuss whether this right can over-ride the requirement to retain data.

Restrict the processing of your personal data under certain circumstances for example:

• To establish the accuracy of the information
• Where the use of data is unlawful but you do not want it to be erased
• Where you need us to hold the data even if I no longer require it as you need it to defend legal claims.
• Where you have objected to our use of your data but I need to verify whether I have overriding legitimate grounds to use it.

Object to processing your personal information if you feel it impacts on your rights and freedoms or feel the processing is carried out on a legal basis other than that outlined in this policy. In some cases I would discuss whether this right can override your rights and freedoms.

Request the transfer of your personal data to you or to another organisation that you may be working with.

Withdraw consent at any time where I am relying on consent to process your personal data. If you withdraw your consent, I may not be able to provide services to you. I will advise you if this is the case at the time you withdraw your consent.

You will not be charged any extra fees if you choose to exercise your data protection rights, In this case, a request will need to be made in writing to the Data Controller, Dr Jyoti Pooni and I will endeavour to respond within one calendar month. Occasionally it could take longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.

Questions about privacy and contact details

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 please contact Dr Jyoti Pooni on:

Telephone: +44 7842 243557

Email address: admin@grow-thepsychologyclinic.com

I take data security extremely seriously and all such communications are examined and replies issued where appropriate as soon as possible. In the majority of cases, I would expect to be able to respond to any questions or comments about how I collect and use your personal data sufficiently to satisfy any concerns you may have. However, if you remain dissatisfied after speaking to me, you may make a complaint to the Information Commissioner’s Office (ICO) using the following contact details:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk