- GENERAL
DATA PROTECTION REGULATION (GDPR) - PRIVACY NOTICE
(1) SCOPE
This document refers to personal
data, which is defined as information concerning any living person (a
natural person who hereafter will be called the Data Subject) that is
not already in the public domain. 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.
(2) WHO WE ARE
For the purposes of this “Privacy Notice” Expert Psychologists Ltd is based at Expert Psychologists Ltd, School House, Mill Lane, Kemberton, Shifnal, Shrophsire TF11 9LH, which hereafter for the purposes of this “Privacy Notice” will be referred to as “Expert Psychologists”, offering psychological services in accordance with the British Psychological Society's standards and guidelines https://www.bps.org.uk/psychologists/standards-and-guidelines.
(3) WHAT IS THIS POLICY FOR
This Privacy Information explains
how Expert Psychologists practices, controls, processes, and protects
all personal information, including details on how personal information is used in the day-to-day
running of Expert Psychologists, including your rights under current
laws and regulations. It applies to the following:
Members of the public contacting
Experts Psychologists by phone, text, email or by post;
Employees, staff and professional
colleagues of Expert Psychologists;
Recipients of psychological
services; and
Members of the public browsing or
using this website.
(4) RESPONSIBILITY FOR DATA PROTECTION
For the purposed of data
protection legislation, The 'Data Controller' is Dr Loumidis, Director
of Expert Psychologists Ltd, (ICO Registration Number Z9737627).
Expert Psychologists Ltd have
appointed Dr K. Loumidis, the Director of Expert Psychologists as
“Privacy and Compliance Officer” who will deal with all
your requests and enquiries concerning the use of your personal data
and try to ensure that all personal data is processed in
compliance with this policy and data protection law.
(5) WHAT IS PERSONAL INFORMATION
Personal data is defined by the General Data
Protection Regulation (EU Regulation 2016/679) (the "GDPR") as 'any
information relating to an identifiable person who can be directly or
indirectly identified in particular by reference to an identifier'.
(6) CATEGORIES OF INFORMATION
We process two categories of information about
you and (where this applies) your dependants: Standard Personal
Information which helps us to contact, identify or manage our
relationship with you; and Special Categories of information, which
helps us to tailor your care.
(7) STANDARD PERSONAL INFORMATION
Standard Personal information includes: contact
information such as name, address, phone numbers and email address; the
country you live in, age, date of birth and national identifiers such
as passport document or National Insurance number, employment details,
details of any contact we had with you such as any complaints or
incidents, financial details which if required, we store your card
details on our secure Sage Pay service for 90 days, which are then
deleted; information about how you use our website, apps, or other
technology, including IP addresses or other device information.
(8) SPECIAL CATEGORY INFORMATION
Special Category information includes information
about your physical or mental health, from notes and reports about your
health and any treatment and care you have received or need, or it may
be recorded in details of contact we have had with you such as
information about complaints or incidents, and referrals from your
existing insurance provider, quotes and records of medical services you
have received); information about your race, ethnic origin and religion
(we may get this information from your medical preferences to allow us
to provide care that is tailored to your needs); and information about
any criminal convictions and offences (we may get this information when
carrying out anti-fraud or anti-money-laundering checks, or other
background screening activity
(9) HOW WE COLLECT PERSONAL INFORMATION
We collect personal information from you and from third parties (anyone
acting on your behalf, for example, solicitor, personal injury
services, insurers etc.).
We collect personal information
from you through your contact with us via phone email, our website or
by post. We also collect information from other people and
organisations.
We collect information from solicitors, rehabilitation agencies or
indirectly from documents provided by them, including reports from
expert witnesses.
We may collect information from a family member or someone acting on
your behalf; doctors, clinicians, health care professionals, hospitals,
clinics and other health care providers; and any service providers who
work with us in relation to your service.
If we provide you with health
care, we may collect information from your employer, your parent or
guardian (if you're under 18 years old), those paying for the products
or services we provide to you including other insurers.
(10) WHAT WE USE YOUR INFORMATION
FOR
Confidentiality
and consent to treatment are core values of our professional practice
and we provide a professional
psychological service. Any information disclosed will be treated with
respect and will be confidential, unless he has serious professional or
ethical reasons for not doing so, in which case he will discuss this
matter with you.
We
use your personal information only for “legitimate interest
purposes” set out in this privacy notice.
We process standard personal
information about you if this is necessary to provide the services set
out in a contract, if this is in our or a third party's legitimate
interest, or if this is required or allowed by law.
We process special category
information about you because it is necessary for the purposes of
health prevention, assessment and treatment services; it is necessary
for insurance purposes; it is necessary to establish, make or defend
legal claims; it is preventing or detecting an unlawful act,
malpractice, dishonesty or other serious improper behaviour; it is in
the public interest; in line with any laws apply; it is information
that you have made public; or/and because we have your permission
(11) LEGITIMATE INTEREST PURPOSES
Expert Psychologists will only collect the
information needed so that we can provide you with the services you
require. The business does not sell, broker, outsource of make
any profit from your data.
For administrative purposes: For the purposes
of booking an appointment, all patients will need to provide personal
information, including their title, name, surname, date of birth,
address, telephone number, mobile number email address, name of GP,
name in insurer (if insured) and financial details. Contact details
provided by you such as telephone numbers, email addresses, postal
addresses may be used to remind you of future appointments and provide
reports or other information concerning your treatment.
For financial and accounting purposes: You
will be required to provide written consent for Expert Psychologists to
contact your insurers, send invoices to your insurers or to any other
third parties paying for your fees. You will need to provide card
details before the first appointment, and a signed form, to take future
payments, unless your fees are paid by others. Separately, Spire and
Nuffield Hospital policies also require that you give them these
details.
For psychological purposes: During the
consultation, psychologists elicit detailed personal, medical and other
psychologically relevant information. We will only collect what is
relevant and necessary for your treatment. This data is always held
securely, is not shared with anyone not involved in your treatment,
although for data storage purposes it may be handled by administrative
staff who have all signed an integrity and confidentiality agreement.
To be able to process your personal data it is a condition of any
treatment that you give your explicit consent to allow psychologists to
document and process your personal medical data.
For marketing purposes: Expert Psychologists
does not use any of your information. The website used by Expert
Psychologists uses cookies. A cookie is a string of information that a
website stores on a visitor's computer, and that the visitor's browser
provides to the website each time the visitor returns. Cookies to help
Expert Psychologists to identify and track visitors and their website
access preferences. Website visitors who do not wish to have cookies
placed on their computers should set their browsers to refuse cookies
before using Expert Psychologists website. Expert Psychologists
will only collect the information needed so that we can provide you
with the services you require, the business does not sell or broker
your data.
For expert witness purposes: If your
solicitors have referred you for an independent psychological report
for the Court, you will be examined by a psychologist acting as an
independent expert witness and not for confidential treatment
purposes. The psychologist’s duty is to the Court and not the
claimant, defendant, or any instructing parties. The report will
contain an independent, unbiased opinion negotiable only in respect of
basic factual detail, although the solicitors may request
clarifications. Copies of the report may be sent to third
parties, solicitors or indeed may be presented in Court and the usual
principles of confidentiality between a patient and a psychologist
cannot be presumed in that instance.
For other business related purposes: Expert
Psychologists may use information for the following purposes: to help
manage our relationship with you, our business and third parties who
provides products or services for us; to provide health care service on
your behalf of a third party; to investigate complaints and incidents;
for statistical research and analysis so that we can monitor and
improve our products and services; to monitor our clinical and
non-clinical performance expectations; to enforce or apply our website
terms of use, our policy terms and conditions or other contracts, or to
protect our (or our customers' or other people's) rights, property or
safety; to exercise our rights, to defend ourselves from claims and to
keep to laws and regulations that apply to us and the third parties we
work with; or to take part in, or be the subject of, any sale,
purchase, merger or takeover of all or part of the Expert Psychologists
business.
(12) CONSENT
Before you see a psychologist, you will be
provided with relevant Terms and Conditions, which you will be
requested to read, consent to and sign.
By visiting the website you are
agreeing to this privacy notice and consenting to Expert Psychologists
processing your personal data for the purposes outlined. You can
withdraw consent at any time by using the postal, email address or
telephone number provided at the end of this Privacy Notice.
(13) DISCLOSURE
Summary: Expert Psychologists will keep
your personal information safe and secure, and only staff engaged in
providing your treatment will have access to your patient records,
although our administration team will have access to your contact
details so that they can make appointments and manage your account.
Expert Psychologists will not disclose your Personal Information unless
compelled to, in order to meet legal obligations, regulations or valid
governmental requests. Expert Psychologists may also enforce its Terms
and Conditions, including investigating potential violations of its
Terms and Conditions to detect, prevent or mitigate fraud or security
or technical issues; or to protect against imminent harm to the rights,
property or safety of its staff.
General principles of data sharing: With
your consent, we share information with doctors, clinicians and other
health-care professionals, hospitals, clinics and other health-care
providers; suppliers who help deliver products or services on our
behalf; people or organisations we have to, or are allowed to, share
your personal information with by law (for example, for
fraud-prevention or safeguarding purposes); the police and other
law-enforcement agencies to help them perform their duties, or with
others if we have to do this by law or under a court order; if Expert
Psychologists sell or buy any business or assets, the potential buyer
or seller of that business or those assets. If we provide you
with health care, with your consent we share information with your
employer, if your employer is paying for the services we are providing;
our insurance partners, for example, solicitors and interpreters; those
paying for the products or services we provide to you; or other
clinicians those providing your treatment
Data for booking appointments: This
information contains your name, contact details, address, name of GP,
who pays for treatment and your email. This is sent to the
receptionist of the consulting rooms where your appointment will be
held.
Data for insured members: We are recognised by
major insurers such as Alliance, Aviva, AXA, Bupa, Cigna, PruHealth,
Simply Health, Vitality, and WPA, as well as other agencies. An
invoice will contain your name, contact details, address,
pre-authorisation number and sometimes your condition.
Data for rehabilitation patients: With your
explicit consent we will send an initial assessment report, progress
reports and an end of treatment report to the rehabilitation agency,
who will then share this with the party paying for your fees.
This information contains your name, contact details, address, name of
your GP, who pays for treatment, your email and clinically sensitive
information.
Limits of confidentiality: You must confirm
that you understand that Dr Loumidis does not operate an emergency or
out-of-hours crisis service. In an emergency, if you (or others) feel
that you could be a risk to yourself or others, you will need to contact your GP, 999
or your local A&E. You must confirm that you understand that
all sessions are confidential, unless there is a serious risk of harm
or neglect to yourself or others. If so, Dr Loumidis
may need to talk to other professionals without your consent.
Data for expert witness services:
In expert witness work, the role of the psychologist is to assess
people an independent expert witness and not for the provision of any
private and confidential psychological assessment or treatment
services. The assessment will include in detail and in depth, both
post-incident as well as pre-incident circumstances. It is
important that you provide Dr Loumidis with a complete and accurate history,
without concealing or minimising the significance of any of your
circumstances. Copies of the report will be sent to third parties,
and/or the Court/Tribunal and the usual patient-psychologist
therapeutic confidentiality does not apply.
Data used in supervision: All psychologists,
irrespective of grade, undertake professional supervision, and you will
need to confirm whether, with your consent, you agree for Dr Loumidis to
anonymously discuss your cases with other professionals.
Data used in clinical correspondence: With
your consent Dr Loumidis will be sending a letter outlining in detail
the content of the assessment, his opinion, your treatment plan,
and
regular updates to your referrer, GP, any professionals involved in
your care, or your insurer (if requested). With your consent Dr
Loumidis
will copy you into any correspondence about your care. With your
consent
Dr Loumidis will be using your details as provided by you, for letters
or any
correspondence.
(14) RETENTION
Expert Psychologists will process personal
data during the duration of any treatment and will continue to store
only the personal data needed for eight years after the contract has
expired to meet any legal obligations.
Afterseven years all personal
data will be deleted, unless basic information needs to be retained by
us to meet our future obligations to you, such as erasure details.
(15) DATA STORAGE
All Data is held in the United
Kingdom. Expert Psychologists does not store personal data outside the
EEA. All data storage services used by Expert Psychologists are fully
GDPR compliant and available on request.
(16) LEGAL BASIS FOR PROCESSING ANY PERSONAL DATA
To meet our contractual
obligations obtained from explicit Patient Consent and legitimate
interest to respond to enquiries concerning the services provided.
(17) YOUR RIGHTS AS A DATA SUBJECT
At any point whilst Expert
Psychologists is in possession of, or processing your personal data,
all data subjects have the following rights:
Right of access: You have
the right to request a copy of the information that we hold about you.
Right of rectification:
You have a right to correct data that we hold about you that is
inaccurate or incomplete.
Right to be forgotten: In
certain circumstances you can ask for the data we hold about you to be
erased from our records.
Right to restriction of
processing: Where certain conditions apply you have a right to
restrict the processing.
Right of portability: You
have the right to have the data we hold about you transferred to
another organisation.
Right to object: You have
the right to object to certain types of processing such as direct
marketing, but this does not apply here because we do not engage in any
direct marketing.
Right to object to automated
processing, including profiling: You also have the right not to be
subject to the legal effects of automated processing or profiling.
Limitation: In the
event that Expert Psychologists refuses your request under rights of
access, we will provide you with a reason as to why, which you have the
right to legally challenge. At your request Expert Psychologists can
confirm what information it holds about you and how it is processed.
(18) HOSTING OF DATA
The website is hosted on a third-party
host solution called Hostgator managed by Streamline Marketing and can
be accessed on expertpsychologists.co.uk. It is designed and
maintained by Streamline Marketing who does not export or use any data
stored on client websites.
(19) YOU CAN REQUEST THE FOLLOWING INFORMATION
You can request the following information:
Identity and the contact details
of the person or organisation (Expert Psychologists) that has
determined how and why to process your data.
Contact details of the data
protection officer, where applicable. The purpose of the
processing as well as the legal basis for processing.
If the processing is based on the
legitimate interests of Expert Psychologists and information about
these interests.
The categories of personal data
collected, stored and processed.
Recipient(s) or categories of
recipients that the data is/will be disclosed to.
How long the data will be stored.
Details of your rights to
correct, erasure, restrict or object to such processing.
Information about your right to
withdraw consent at any time.
How to lodge a complaint with the
supervisory authority (ICO).
Whether the provision of personal
data is a statutory or contractual requirement, or a requirement
necessary to enter into a contract, as well as whether you are obliged
to provide the personal data and the possible consequences of failing
to provide such data.
The source of personal data if it was not collected directly from you.
Any details and information of
automated decision making, such as profiling, and any meaningful
information about the logic involved, as well as the significance and
expected consequences of such processing.
(20) CLINICAL RESEARCH AND
STATISTICAL PURPOSES
We may use anonymised information
or information that is combined with other people's information for
clinical research and statistical purposes, which is subject to
approval from the relevant Research Ethical Committees, in line with
BPsS Guidelines. You cannot be identified from this information.
(21) DATA SECURITY AND PROTECTION
We ensure the security of any
personal information we hold by using secure data storage technologies
and precise procedures in how we store, access and manage that
information. Our methods meet the GDPR compliance requirement.
(22) INTERNET COOKIES
We use cookies to track your
visit for statistical analysis, allowing us to improve the usability,
speed and security of our website. We do not use cookies to
collect any personal identifiable information or sensitive information
(without your consent).
Cookies that we use are Google
Analytics which is an analytics tracking service called Google
Analytics, which is a web analytics service that provides statistics
and basic analytical tools for search engine optimization (SEO) and
marketing purposes.
Google Analytics uses web beacons
from your web browser and IP address to collect information and monitor
the actions you take on the company's website such as the web pages
viewed and links clicked. Google Analytics collects no personal
information.
(23) HOW CAN ACCESS YOUR PERSONAL DATA
If you want to know what personal
data we have about you, you can ask us for details of that personal
data and for a copy of it (where any such personal data is held). This
is known as a "subject access request".
Subject Access Request:
All subject access requests should be made in writing and sent to the
email or postal addresses shown. There is a nominal
administrative charge for a subject access request. If your request is
'manifestly unfounded or excessive' (for example, if you make
repetitive requests) further fees may be charged to cover our
administrative costs in responding. We will respond to your
subject access request within 40 working days of receiving it.
Normally, we aim to provide a complete response, including a copy of
your personal data within that time. In some cases, however,
particularly if your request is more complex, more time may be required
up to a maximum of three months from the date we receive your request.
You will be kept fully informed of progress.
Limitations: In some
cases, where you are involved in litigation and access to your data may
undermine a medico legal case it may be necessary to inform the
solicitors and the Court involved in the case, and their approval
sought, before such data can be provided. Claimants should note that in
a medico legal case the solicitor requesting the assessment (and
ultimately the Court) is also the data controller in a legal case and
therefore a subject access request may have to be made to more than
Expert Psychologists Ltd for access to the data it holds on you and may
be denied by the solicitor or the Court if access to that data, at that
time, may undermine a legal case.
(24) WHAT WE NEED BEFORE YOU CAN ACCESS YOUR
PERSONAL DATA
To access what personal data is
held, identification will be required. Expert Psychologists will
accept the following forms of identification (ID) when information on
your personal data is requested: a copy of your driving licence,
passport or birth certificate, together with a utility bill not older
than three months. A minimum of one piece of photographic ID listed
above and a supporting document is required. If Expert Psychologists is
dissatisfied with the quality, further information may be sought before
personal data can be released.
All
requests should be made by
email via the website, or by phoning 07738 559 114, or by writing
to us at Expert Psychologists Ltd, School House, Mill Lane, Kemberton,
Shifnal, Shrophsire TF11 9LH. If you do not hear back from uswithin five days please try another form of contact.
(25) COMPLAINTS
In the event that you
wish to make a complaint about how your personal data is being
processed by Expert Psychologists you have the right to complain to us.
If you do not get a response
within 30 days, you can complain to the ICO. The details for each of
these contacts are:
Dr Loumidis, Director of Expert PsychologistsLtd, School House, Mill Lane, Kemberton, Shifnal, Shrophsire TF11 9LH
ICO Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 https://ico.org.uk
(26) UPDATED VERSION
We may change this policy from time to time by
updating this page. You should check this page from time to time to
ensure that you are happy with any changes.
- TERMS AND CONDITIONS FOR USING
THE WEBSITE: http://www.ExpertPsychologists.co.uk
The following Terms and Conditions apply to the use of the http://www.ExpertPsychologists.co.uk site. These terms and conditions govern your use of our website; by using our website, you accept these terms and conditions in full. If you disagree with any part of these terms and conditions, do not use our website. Expert Psychologists Ltd is committed to protecting your privacy. This Privacy Policy explains our data processing practices and your options regarding the ways in which your personal data is used. If you have any requests concerning your personal information or any queries with regard to our processing please contact us via our website site http://www.ExpertPsychologists.co.uk .
(1) INTRODUCTION
The site http://www.ExpertPsychologists.co.uk
is owned and operated by Expert Psychologists Ltd.
(2) INTELLECTUAL
PROPERTY RIGHTS
Unless otherwise stated, we own the intellectual property rights in the
website and material on the website. Subject to the licence below, all
our intellectual property rights are reserved.
(3) LICENCE TO USE
THE WEBSITE
You may view, download for caching purposes only, and print pages from
the website but only for your own private use and not for any profit
making or other commercial purposes.
The information provided on this site is not intended nor recommended as a substitute for professional medical, clinical or other psychological advice. Always seek the advice of your physician or other qualified health care professional regarding any medical condition or treatment. Nothing contained on this site is intended to be used for medical diagnosis or treatment.
(4)
LIMITATIONS OF LIABILITY
The information on this website
is provided free-of-charge, and you acknowledge that it would be
unreasonable to hold us liable in respect of this website and the
information on this website.
Whilst we try to ensure
that the information on this website is correct, we do not warrant its
completeness or accuracy; nor do we not commit to ensuring that the
website remains available or that the material on this website is kept
up-to-date.
To the maximum extent permitted
by applicable law we exclude all representations, warranties and
conditions (including, without limitation, the conditions implied by
law of satisfactory quality, fitness for purpose and the use of
reasonable care and skill).
Our liability is limited and
excluded to the maximum extent permitted under applicable law. We will
not be liable for any direct, indirect or consequential loss or damage
arising under these terms and conditions or in connection with our
website, whether arising in tort, contract, or otherwise - including,
without limitation, any loss of profit, contracts, business, goodwill,
data, income, revenue or anticipated savings.
However, nothing in these terms
and conditions shall exclude or limit our liability for fraud, for
death or personal injury caused by our negligence, or for any other
liability which cannot be excluded or limited under applicable law.
(5) VARIATION
We may revise these terms and conditions from time-to-time. Please
check this page regularly to ensure you are familiar with the current
version.
(6) ENTIRE AGREEMENT
These terms and conditions, together with our privacy policy constitute
the entire agreement between you and us in relation to your use of our
website, and supersede all previous agreements in respect of your use
of this website.
(7) LAW AND
JURISDICTION
This notice will be governed by and construed in accordance with
English law, and any disputes relating to this notice shall be subject
to the exclusive jurisdiction of the courts of England.
(8) THIRD PARTY WEBSITES
The website contains links to other websites. We are not responsible
for the privacy policies of third party websites.
(9) SECURITY OF EMAIL
DATA
We will take reasonable precautions to prevent the loss, misuse or
alteration of your personal information. Of course, data transmission
over the internet is inherently insecure, and we cannot guarantee the
security of data sent over the internet.
(10) OUR CONTACT
DETAILS
Expert Psychologists Ltd, Registered Office is
a tExpert Psychologists Ltd, School House, Mill Lane, Kemberton, Shifnal, Shrophsire TF11 9LH