It is essential that you read this notice, together with any other documents we may provide when we are collecting or processing personal information about you so that you are aware of how and why we are using such information.
The General Data Protection Regulation (GDPR) Personal Data
Personal data is data which relates to any living individual who can be identified from that data, or from that data and other information; such as an expression of opinion about the individual.
What is the GDPR?
The General Data Protection Regulation 2018 (GDPR) replaces the Data Protection Act 1998 (DPA) in governing how personal data is managed by a “controller” or “processor”.
In this respect, a data controller is a person (or business) who determines the way in which, personal data is processed. A data processor is anyone who processes personal data on behalf of the data controller (not including the data controller’s employees).
A “Data Subject” is a person whose data is being processed.
Psychology Expressions is both a controller and processor of personal data. This means that we are responsible for deciding how we hold and use personal information about you, whether you use our services directly or via a third-party.
Under the GDPR, the data protection principles set out the main responsibilities for organisations.
GDPR requires that personal data shall be:
Processed lawfully, fairly and in a transparent manner. Collected for specified, explicit and legitimate purposes. Adequate, relevant and limited to what is necessary. Accurate and, where necessary, kept up to date. Kept in a form which permits identification of data subjects for no longer than is necessary. Processed in a manner that ensures appropriate security of the personal data.
It also requires that the controller shall be responsible for, and be able to demonstrate, compliance with the principles.
The GDPR provides the following rights for individuals:
The right to be informed – Psychology Expressions must provide details (such as those provided in this privacy notice) of how Psychology Expressions processes information to the data subject. This information must be available at any time personal data is obtained.
The right of access – Data subjects have the right to know what information Psychology Expressions has in relation to them. Data subjects then have the right to access this information.
The right to rectification – Data subjects have the right request we update inaccurate or incomplete information that is being processed or stored by Psychology Expressions. We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you do not believe this is the case, you can request for us to update or amend it.
The right to erasure – Data subjects have the right to request we delete any information Psychology Expressions have in relation to them. However, as a private medical practice, we also have a legal duty to retain medical records for a period of time in line with UK law and guidelines, or if other legal obligations bind us.
The right to restrict processing – Data subjects have the right to block or suppress Psychology Expressions processing their information. However, it may be necessary to keep your information in order to perform a task which is in the public interest or for the purposes of establishing, exercise or defending legal claims.
The right to data portability – Data subjects can request that Psychology Expressions make their information available to move, copy or transfer personal data easily from one environment to another.
The right to object – Data subjects can object to processing their information for activities such as marketing.
Individuals also have rights in relation to automated decision making and profiling. However, Psychology Expressions does not carry out this type of processing.
Who Is Collecting Your Information?
Psychology Expressions is the trading name of Consultant Psychologist, Ms Ranjit Mann CPsychol. AFBPsS
Business Correspondence Address:
BMI Syon Clinic
941 Great West Rd,
Middlesex TW8 9DU
Call: +44 (0)7949 515 349
Email: Please visit Psychology Expression’s contact page.
Any information collected or produced as part of these services will be managed in accordance with Psychology Expression’s information security policies and procedures.
Psychology Expression’s Lawful Basis for Processing Data
Psychology Expressions acts as both controllers and processors of personal information.
As controller, Psychology Expressions’s processing activities include arranging appointments between data subjects (patients) and clinicians (doctors, physiotherapists, occupational health practitioners, etc.) for the purposes of consultation, examination, treatment, diagnostic and/or medical management services.
In arranging an appointment, the legal basis for Psychology Expressions processing personal data, such as a data subject’s name, contact details, date of birth, will be contractual. It will be an informal contract between the data subject and Psychology Expressions with the understanding that Psychology Expressions will provide a medical service in exchange for payment. The data subject or their representative will be advised of this arrangement at the time of booking, as well as their rights in relation to processing their information.
Psychology Expressions may also request that you consent to us contacting you with information relating to your service or other services we provide.
As processor, Psychology Expressions’s processing activities include arranging appointments between third-party referrers acting on behalf of an individual data subject and Psychology Expressions consultants. Where data is collected from third-parties, there will be a contractual agreement between Psychology Expressions and the third-party.
Special Category Data - Second Lawful Basis
Information about an individual, that is likely to be of a sensitive or private nature and could be used in a discriminatory way, is described as sensitive personal information and identified as special category data. This type of information needs to be treated with greater care than other forms of personal data.
Sensitive personal information may include:
- Racial or ethnic origin
- Political opinion
- Religious or other similar beliefs
- A physical or mental health or condition
- Sexual Orientation
When a data subject presents for an appointment, they will be required to provide, or a clinician may generate/obtain and document information that may contain sensitive or special category data, including information relating to a physical or mental health or condition.
Second Lawful basis for processing special category data
Special category data is personal data which the GDPR says is more sensitive, and so needs more protection. When processing special category data, Psychology Expressions must identify both a lawful basis under Article 6 and a separate condition for processing special category data under Article 9.
In accordance with GDPR Article 9, relating to special category information, the most appropriate lawful basis for Psychology Expressions in processing this kind of data is that processing is: “Necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of an employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services.”
However, you may be asked to provide consent before or during an appointment where special category information may be obtained and/or processed.
Consent needs to be clear, concise, specific, granular, explicit, separate from other terms and conditions and will require the data subject to positively opt-in. Consent forms will be periodically and routinely reviewed and updated to ensure they remain relevant and applicable to the process for which it is required.
We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so.
Requirements for sharing special category data with third-parties
Psychology Expressions may act as a processor of personal data but become a controller in obtaining special category data during an appointment. Psychology Expressions may also be a controller and need to transfer information to a third-party where the third-party acts as a processor. In these instances:
Third-parties will be identified to the data subject prior to transfer of information. Consent may be required for Psychology Expressions to share personal information with third-parties, irrespective of their original role. Third-parties will be required to have a contractual agreement with Psychology Expressions. As part of this contract, third-parties will be required to demonstrate that they have attained a suitable level of information security and have met the standards set by GDPR in acting as a processor.
Psychology Expressions will not routinely transfer information outside of the EU. However, upon request from the data subject, Psychology Expressions may be required to do so. In this situation, Psychology Expressions will again need to ensure that there are adequate safeguards in place and that the recipient has a suitable level of information security and meet the same standards set by GDPR.
How Personal Data is Collected
Psychology Expressions will collect personal data:
- Indirect communications (such as website, telephone, letter or video) either with the data subject or a third-party controller.
- When a data subject completes a consent form, contact form, template, questionnaire, survey or registration form, either directly from the data subject or via a third-party.
- When a clinician completes a clinical record or report as part of a consultation/appointment.
- As part of a third-party instruction or referral where Psychology Expressions is a processor.
- As part of a clinical record obtained from a third-party, such as a diagnostic test result, screen or clinical specialist/expert/consultant where Psychology Expressions is the original controller and referrer.
- As part of financial processing.
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What Personal Data Is Being Collected or Generated?
Psychology Expressions will need to obtain a minimal amount of personal data to:
- Contact a data subject, provide details of an appointment.
- When Psychology Expressions need to make changes to an appointment.
- Identify the data subject in relation to their own existing medical record(s).
The type of information includes:
- Information that you provide when you enquire become a customer, patient or apply for a job.
- Details of correspondence.
- The name and contact details of your next of kin/parent/guardian.
- Details of service or treatment you have received from us.
- Notes, records or reports relating to your health and/or treatment you have received.
- The information you provide when you make a payment, such as financial or credit card information. We Do not store credit/debit card information unless we have your consent.
Data subjects are permitted to arrange appointments anonymously. However, the data subject will need to provide identifiable details, which will need to be recounted in communications with Psychology Expressions to provide a regular service, such as receiving results.
The minimum amount of personal data a data subject’s is required to provide is contact information, name and date of birth. However, as part of an appointment, a clinician may also need to obtain or create sensitive personal information about a data subject, which includes information relating to a physical or mental health condition. Psychology Expressions may also refer to previous medical opinion (such as medical records). Psychology Expressions may also request further investigations and/or opinion in the form of a diagnostic screen result or report from a clinical specialist/expert/consultant.
The amount of information required will vary depending on individual circumstances, symptoms or requirement. However, the personal data required will be proportional and relevant. For instance, Psychology Expressions may require a complete family medical history from data subject’s undertaking a health assessment or Psychology Expressions may need to know whether a data subject is pregnant prior to administering or prescribing medication.
Data subjects are not compelled to provide any information. However, if you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you or we may be prevented from complying with our legal obligations. Withholding or providing inaccurate information may also affect the ability of our clinicians to provide an effective and safe service.
How Will Personal Data Be Used?
The information Psychology Expressions collect will be confidential and only ever be used for the purposes of undertaking or providing consultation, treatment, immunisation, examination, diagnostic and/or medical management services. As part of these services, Psychology Expressions may require personal information to create appointments and to convey or record medical opinion.
Psychology Expressions will not use or pass on personal data to market services that are unrelated to those that have been consented. However, with consent, Psychology Expressions may use personal data to inform a data subject about a follow-up or related service.
Sensitive personal data will only be disclosed to those involved with your appointment, care, in accordance with UK laws and guidelines of professional bodies or for the purpose of clinical audits.
We may use your personal data to:
Full-fill our obligations to you in relation to a contractual agreement to provide a service, including financial obligations. Provide you with information about products or services that we provide. Notify you about a change to the service requested. Respond to a request. Ensure the accuracy of information we hold about you. Support a healthcare professional or clinician directly involved in your care. Assess the quality of service you have received.
Where is personal data stored?
Information is either stored as an electronic record, on a central database or as a hardcopy (paper record) at Psychology Expressions’s main administration centre. Information may be processed externally on-site or at one of Psychology Expressions’s clinic locations, so long as use abides to Psychology Expressions’s information security and Remote Working policy. A secure back-up of information is also stored externally, by an ISO accredited IT support provider.
Personal data, including special category data, may be stored temporarily as part of communications, such as email or in a hardcopy transferable format, such as a data disk or paper record.
Who Will It Be Shared With?
With consent, Psychology Expressions may share information with third-parties for further investigation and/or specialist opinion. Examples of third-parties include:
Clinical experts, specialists or consultants, screening centres or laboratories, solicitors or agencies where Psychology Expressions is originally acting as processor and employers who refer to Psychology Expressions for occupational health opinion.
Anonymised information may be made available to Healthcare Inspectorate Wales (HIW) or Care Quality Commission (CQC) as part of a healthcare inspection to ensure that Psychology Expressions meets the requirements set by the government provide private healthcare services.
Psychology Expressions may also need to make information available on the basis of necessity. For instance, in an emergency, we may need to process your personal data (including sensitive personal data) or make personal data available to third parties on the basis of protecting your “vital interest” (i.e. your life or your health).
In providing a service, we may disclose your personal data to third-parties, including:
Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you. Organisations providing IT systems support and hosting in relation to the IT systems on which your information is stored. Third-party service providers for the purposes of storage of information and confidential destruction, third-party marketing companies for the purpose of sending marketing emails, subject to obtaining appropriate consent.
Where a third party data processor is used, we ensure that they operate under contractual restrictions with regard to confidentiality and security, in addition to their obligations under Data Protection Laws.
The Removal of Information
Data subjects have the right to withdraw consent or request a copy/transferal/removal of certain information by requesting Psychology Expressions’ Consent Removal form. However, as a healthcare provider, we may not be legally able to complete your request to restrict the processing or deletion of.
|Type of patient||Minimum period of retention|
|Patient who was under the age of 17 at the date on which the treatment to which the records refer was concluded.||Until the patient’s 25th birthday|
|Patient who was aged 17 at the date on which the treatment to which the records refer was concluded.||Until the patient’s 26th birthday|
|Patient who died before attaining the age of 18.||A period of 8 years beginning on the date of patient’s death.|
|Patient who was treated for a mental disorder during the period to which the records refer.||A period of 20 years beginning on the date of the last entry in the record.|
|Patient who was treated for a mental disorder during the period to which the records refer and who died whilst receiving that treatment.||A period of 8 years beginning on the date of the patient’s death|
|Patient whose records relate to treatment by a general practitioner.||A period of 10 years beginning on the date of the last entry in the record|
|All other cases||A period of 8 years beginning on the date of the last entry in the record|
Suspected breaches in data protection can be reported to Psychology Expressions’s Data Protection officer Ms Ranjit Mann CPsychol. AFBPsS.
Breaches in Data Protections will result in Psychology Expressions producing an incident investigation. Serious breaches will be reported to the Information Commissioner’s Office (ICO). You retain the right to report a breach to the ICO directly – https://ico.org.uk/for-organisations/report-a-breach/
It is the responsibility of all Psychology Expressions employees and contractors to report suspected breaches of information security to Psychology Expressions department heads, IT department, and/or Data Protection Officer without delay.