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Manchester Psychologist: Privacy Policy

The basics:
I keep information about you in order to provide you with a service, and to process payments. I cannot work with you unless you allow me to keep records. I follow the law, and the codes of practice set down by my professional regulator, the UK Health and Care Professions Council (HCPC).

I have systems in place to protect your data. You are entitled to request a copy of your data free-of-charge, and to have inaccurate information corrected. I aspire to the highest data privacy standards. If you have questions, concerns or feedback then please let me know so that I can address them.

Why I keep information:
My professional registration requires me to keep information about my clients and the work that I do. I cannot offer you services unless you allow me to keep data about you and our work together.

The legal basis:
I have what is known as a legitimate interest for keeping data. I also seek explicit consent from all of my clients.  I follow the rules set down by the HCPC.

The information that I keep:
I keep personal data e.g. your name, address, phone number. I also keep sensitive data e.g. notes about our meetings, social history etc.

I do not keep any sensitive information about you if you make an initial enquiry and then do not proceed with a service from me.

What I do with the information:
I use the data I collect for three reasons: (1) to provide you with services, (2) for billing and processing payments (3) to help prevent serious harm.

Information Shared with Third parties

• If you choose to proceed with a service, I will ask you for contact details for your GP and your permission to contact your GP and any other health professionals currently involved in your care as required during the course of therapy. This may include informing them that you are being seen by the service, details of the reasons why and other need-to-know information about your health and wellbeing.  Unless there are concerns about risk of harm to yourself or others, you will be able to review and approve/request changes to all information before it is shared with third parties.
• Confidentiality may be breached only in order share with appropriate other agencies where there are concerns about risk of harm to self or others, or where disclosure is required by law (e.g. for safeguarding purposes). Consent is not necessary for this but will be sought from you wherever possible.  In exceptional circumstances, we might need to share personal information with relevant authorities.
• I have a Virtual Assistant who manages invoicing and billing on my behalf and helps to manage my diary.  She will have access to your personal information (e.g. your name, address, date of birth, insurance details etc.) appointment schedules and payment information.  She will not have access to any sensitive information about you (e.g. information about our meetings or any emails you send).  She only processes your data on my instruction and is subject to a duty of confidentiality in line with legal (GDPR) requirements.
• If you are referred by your 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.
• In cases where treatment has been instructed by a solicitor, relevant clinical information from therapy records will be shared with legal services as required and with your written consent.
• Anonymised, non-identifying information about you may be verbally shared with a clinical psychologist colleague in a confidential setting for the purpose of clinical supervision. Clinical supervision is an essential aspect of clinical psychologists’ work for best practice and clinical governance purposes.  Any notes arising from supervision discussions will be entered into your clinical notes file.
• In the event that I die or become incapacitated during the course of therapy, my professional executor may take control of records and contact you to inform you of the situation.  My therapy will document is held by a senior clinical psychologist colleague who will manage these conversations sensitively and who is bound by the same professional and ethical regulations as our practitioners.  They will maintain your confidentiality and will not disclose any of your information except as already detailed in this section.

Contacting You

I will contact you only for the following reasons:

• To set up /change appointment times
• To send you information related to your appointment and therapy (e.g. venue information or psychological information linked to therapy)
• To help solve payment problems
• If concerns about risk to self or others arise

You will be asked your preferred method of contact (post, email, telephone) and if a voicemail/text message can be left.  Please notify me of any restrictions you would like to impose to protect your privacy.

How long I keep data: 

I keep client data throughout the time I work with my clients and, in line with professional guidance for 7 years after the work has ended (guidance references below).  After this point all information will be securely destroyed.

[1]The British Psychological Society (2000). Clinical Psychology and Case Notes: Guidance on Good Practice. Leicester: Division of Clinical Psychology, BPS.

[2]Health and Care Professions Council (2017). Confidentiality – guidance for registrants. London: HCPC.

Where I keep data: 

• In online clouds: in my clinic management software Writeupp (writeup.com) and in my file storage cloud: G Suite (gsuite.google.com)
• On my desktop computer
• On a ReMarkable writing tablet (temporarily)
• In my mobile phone
• In my email systems

How I keep data safe: 

• Writeupp data is encrypted using 256-bit SSL encryption. My account is locked with a strong password and two-factor verification.
• G Suite data is encrypted using 128-bit or stronger Advanced Encryption Standard (AES). Google encrypts core G Suite data while it is “in transit”, whether it is traveling over the Internet between the customer and Google, or moving within Google as it shifts from one data centre to another.
• My computer is password-protected with appropriate antivirus, malware and firewall protection.
• ReMarkable is password protected and all notes are regularly downloaded and saved into clinical notes and then deleted from this device.
• My mobile phone is encrypted, and must be opened with a password/fingerprint each time I use it.
• My email systems are secured with a password. I save a copy of emails in clinical notes and then delete emails from my email system as soon as they are no longer required.

You have the right to: 

• request details of all the information that I keep and to receive it within one month at no fee.
• have information corrected if you consider it inaccurate or incomplete and complain if you think that I am acting unlawfully (see The basics, above).
• To end therapy at any point and request no further contact from me.

If you have any questions about this statement:

Please feel free to contact us.

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Last updated 09 September 2024