PATIENT PRIVACY NOTICE
1. As your treating
clinician and therefore custodian of personal information relating to your
psychological treatment, I must treat that information in accordance with all
applicable law and guidance. This Privacy Notice provides you with a detailed
overview of how I will manage your data, from the point at which it is gathered
and onwards. I will use that information for a variety of purposes including,
but not limited to, providing you with care and treatment, sharing it with
other healthcare professionals and seeking feedback on your patient
experience. This Privacy Notice will give
you all the details you need on how I will use your information, and how I will
comply with the law in doing so.
2. In addition, you have a number of rights as
a data subject. You can, for instance, seek access to your healthcare
information, object to me using your information in particular ways and request
rectification of any information which is inaccurate, or deletion of
information which is no longer required (subject to certain exceptions). This
Privacy Notice also sets out your rights in respect of your personal
information and how to exercise them.
3. For ease of reference, this Privacy Notice
is broken into separate sections below with headings which will help you to
navigate through the document.
1. This Privacy Notice sets out
details of the information that I, as a clinician responsible for your
treatment (and including my secretary) may collect from you and how that
information may be used. Please take your time to read this Privacy Notice
2. In this Privacy Notice I use “I” or “mine”
or “my” to refer to me as the clinician who is using your personal information.
3. In the event that you have any queries, comments or concerns in respect
of the manner in which I have used, or potentially will use, your personal
information I would be happy to discuss this further. You can call my secretary, Sarah Bryant, on
07756 537290 and request a call back from me.
Your personal data
will provide your treatment from a Spire Healthcare Hospital or other
independent provider and, in due course, it may be necessary for Spire or other
independent provider to also process your personal data. I will do so in accordance with the law, the
principles of this Privacy Notice and to the extent that it is necessary to do
so. This could be where Spire or other
independent provider needs to arrange other healthcare services as part of your
treatment, or support other aspects of the treatment which I provide to
you. In that case, Spire or other
independent provider will become a joint Data Controller in respect of your
personal information and you will be provided with a copy of their Privacy
Notice which sets out how they will manage that information.
personal information will be handled in accordance with the principles set out
within this Privacy Notice. This means that whenever I use your personal data,
I will only do so as set out in this Privacy Notice. From time to time, I may process your
personal information at a non-Spire or other independent provider site, as may
my medical secretary.
What personal information do I collect
and use from patients?
will use “special categories of personal information” (previously known as "sensitive personal data") about you, such as information
relating to your physical
and mental health.
you provide personal information to me about other individuals (including medical or financial information) you
should inform the individual about the contents of this Privacy Notice. I will also process such information in accordance with this Privacy Notice.
addition, you should note that in the event you amend data which I already hold about you then I will update our systems to
reflect the amendments. Our systems will continue to store historical data.
one of my patients / clients, the personal information I hold about you may include the following:
Contact details, such as postal address, email address and
telephone number (including mobile number)
Financial information and insurance policy details
Emergency contact details, including next of kin
Background referral details
Special Categories Personal Information
11. As one of my patients / clients, I will hold information relating
to your psychological treatment which is known as a special
category of personal data under the law, meaning that it
must be handled even more sensitively.
This may include the
a) Details of
your current or former physical or mental health, including information about
any healthcare you have received from other healthcare providers such as GPs,
dentists or hospitals (private and/or NHS), which may include details of clinic
and hospital visits, as well as medicines administered. I will provide further
details below on the manner in which I handle such information.
b) Details of
services you have received from me
c) Details of
your nationality, race and/or ethnicity
d) Details of
concerning your sex life and/or sexual orientation
confidentiality of your medical and psychological information is important to me, and I make every effort to
prevent unauthorised access to and use of information
relating to your current or former physical and mental health (or indeed any of your personal
information more generally). In doing so, I will comply with UK data protection law, including the Data
Protection Act 2018 and all applicable
confidentiality guidelines issued by professional bodies.
25 May 2018, the current Data Protection Act will be replaced by the EU
General Data Protection Regulation (GDPR) and a new Data Protection Act. All uses of your information
will comply with the GDPR and the new Data Protection
Act from that date onwards
How do I collect your information?
may collect personal information from a number of different sources including,
but not limited to:
hospitals, both NHS and private, including Spire or other independent providers
of healthcare services
clinicians (including their medical secretaries)
Directly from you
may be collected directly from you when:
a) You enter into a contract with me, or Spire,
or another independent provider
for the provision of healthcare services
b) You use those services
c) You complete
enquiry forms on the Spire website, the Psynergy website or
the website of another
d) You submit a
query to me including by email
e) You correspond
with me by letter, email or telephone
From other healthcare organisations
16. My patients / clients will usually
receive healthcare from other organisations, and
so in order to provide you with the best treatment possible I may be in receipt of personal information
about you from them. These may include:
a) Medical records
letters and records from your GP
b) Medical letters
and records from other clinicians (including their medical secretaries)
c) Medical letters
and records from other private healthcare organisations
17. Medical records include information about
your diagnosis, clinic and hospital visits and medicines administered.
From third parties
18. As detailed in the previous section, it is often
necessary to seek information from
other healthcare organisations. I may
also collect information about you from
third parties when:
a) You are referred
to me for the provision of services including healthcare services
b) I liaise with your employer, learning institution,
health professional or other treatment
or benefit provider
c) I liaise with your family
d) I liaise with your insurance policy provider
e) I deal with experts (including medical experts) and
other service providers about services you have
received or are receiving from me
f) I deal with NHS health service bodies about services
you have received or are receiving from us
g) I liaise with debt collection agencies
h) I liaise with HMRC
How will I communicate with you?
19. I may communicate with you in a range of
ways, including by telephone, SMS, email, and/or post. If I contact you using the telephone
number(s) which you have provided (landline and/or mobile), and you are not
available which results in the call being directed to a voicemail and/or
answering service, I may leave a voice message on your voicemail and/or
answering service as appropriate, and including only sufficient basic details
to enable you to identify who the call is from, very limited detail as to the
reason for the call and how to call me back.
to ensure that I provide you with timely updates and reminders in relation to your healthcare (including basic
administration information and appointment information (including reminders)),
I may communicate with you by SMS and/or unencrypted email (where you have
provided me with your SMS or email address)
In each case where you have expressed a preference in the patient
registration form to be contacted by SMS and/or email.
to provide you with your clinical information and/or invoicing
information, I may communicate with you by email (which will be encrypted)
where you have provided me with your email address and have expressed a
preference in the patient registration form to be contacted by email. The first time I send you any important
encrypted email that I am not also sending by post or which requires action to
be taken, I will, or my secretary will, endeavour to contact you separately to
ensure that you are able to access the encrypted email you are sent.
21. Please note that although providing your
mobile number and email address and stating a preference to be communicated by
a particular method will be taken as an affirmative confirmation that you are
happy for us to contact you in that manner, I am not relying on your consent to
process your personal data in order to correspond with you about your treatment.
As set out further below, processing
your personal data for those purposes is justified on the basis that it is
necessary to provide you with healthcare service.
What are the purposes for which your
information is used?
22. I may 'process' your information for a
number of different purposes, which is essentially the language
used by the law to mean using your data. Each time I use your data I must have a legal
justification to do so. The particular justification will depend
on the purpose of the proposed use of your data. When the information that I process
is classed as a “special category of personal information”, I
must have a specific additional legal justification in order to use it as
23. Generally I will
rely on the following legal justifications, or ‘grounds':
a) Taking steps at your request so that you can enter
into a contract with me to receive psychological
services from me.
b) For the purposes of providing you with healthcare
pursuant to a contract between you and I. I will rely on this for activities
such as supporting your psychological treatment or care and supporting
other healthcare professionals involved in your care as
c) I have an appropriate business need to process your
personal information and such business need
does not cause harm to you. I will rely on this for activities such as quality assurance, maintaining my
business records, monitoring outcomes and responding to any complaints.
d) I have a legal or regulatory obligation to use such
e) I need to use such personal information to establish,
exercise or defend my legal rights.
f) You have provided your consent to my use of your personal
24. Note that failure to provide your
information further to a contractual requirement with me may
mean that I am unable to set you up as a patient / client or facilitate the provision of your
25. I provide further detail on these grounds in
the sections below.
Appropriate business needs
26. One legal ground for processing personal
data is where I do so in pursuit of legitimate
interests and those interests are not overridden by your privacy rights. Where I refer to use for my appropriate
business needs, I am relying on
this legal ground.
The right to object to
other uses of your personal data
27. You have a range of rights in respect of
your personal data, as set out in detail in sections. This includes the right to object to me using
information in a particular way (such as sharing that information with third parties), and I must stop using
it in that way unless specific exceptions apply.
This includes, for example, if it is necessary to defend a legal claim brought
against me, or it is otherwise necessary for the purposes of your ongoing treatment.
You will find details of my legal
grounds for each of our processing purposes below. I have set out individually those purposes
for which I will use your personal information, and under each one I set out
the legal justifications, or grounds, which allow me to do so. You will note that I have set out a legal
ground, as well as an 'additional' legal ground for special categories of
personal information. This is because I
have to demonstrate additional legal grounds where using information which
relates to a person's healthcare, as I will be the majority of the times I use
your personal information.
Purpose 1: To set you up as my patient,
including regulatory checks
is common with most business, I have to carry out necessary checks in order
for you to become a patient. These
include standard background checks, which I cannot
perform without using your personal information.
ground: Taking the necessary steps so that you can enter into a contract with me for
the delivery of healthcare.
legal ground for special categories of personal information: The use is necessary for reasons
of substantial public interest, and it is also
in my legitimate interests to do so.
Purpose 2: To provide you with
healthcare and related services
the reason you come to me is to provide you with healthcare and so I have to use your personal
information for that purpose.
a) Providing you with healthcare and related
b) Fulfilling my contract with you for the
delivery of healthcare
33. Additional legal grounds for special
categories of personal information:
a) I need to
use the data in order to provide healthcare services to you
The use is necessary to
protect your vital interests where you are physically or legally incapable of giving consent
Purpose 3: For account settlement purposes
34. I will use your personal information in order to ensure that your
account and billing is fully accurate and up-to-date
35. Legal grounds:
a) My providing your healthcare and other
b) Fulfilling my contract with you for the
delivery of healthcare
c) My having an appropriate business need to
use your information which does not overly prejudice you
Purpose 4: For clinical audit
may process your personal data for the purposes of local clinical audit – i.e.
an audit carried out by
myself or my direct team for the purposes of assessing outcomes for patients and identifying improvements which
could be made for the future. I am able to do so on the basis of my
legitimate interest and the public interest
in statistical and scientific research, and with appropriate safeguards in place. You are, however, entitled to object to my
using your personal data for this purpose,
and as a result of which I would need to stop doing so. If you would like to raise such an objection then please contact me using the
details provided in paragraph
5: Communicating with you and resolving any queries or complaints that you
37. From time to time, patients may raise
queries, or even complaints, with me and
Spire/other independent provider and I take those communications very seriously. It is important that I am able to resolve
such matters fully and properly
and so I, as well as Spire/other independent provider will need to use your personal information
in order to do so.
38. Legal grounds:
a) Providing you with healthcare and other
Having an appropriate business need to use your information which does not overly prejudice you
39. Additional legal grounds for special
categories of personal information:
a) The use is necessary for the provision of
healthcare or treatment pursuant to a contract with a health professional
The use is necessary in order for me to establish, exercise or defend my
6: Communicating with any other individual that you ask us to
update about your care and updating other healthcare professionals
about your care.
40. In addition, other healthcare professionals
or organisations may need to know
about your treatment in order for them to provide you with safe and effective
care, and so I may need to share your personal information with them. Further details on the third parties who may
need access to your information is set out at section [TBC] below.
41. Legal grounds:
Providing you with healthcare and other related services
b) I have a
legitimate interest in ensuring that other healthcare professionals who are
routinely involved in your care have a full picture of your treatment
legal ground for special categories of personal information:
a) I need to use the data in order to provide
healthcare services to you
The use is necessary for reasons of substantial public interest under UK
The use is necessary in order for me to establish, exercise or defend my
Purpose 7: Complying with our legal or regulatory obligations, and
defending or exercising our legal rights
43. As a provider of healthcare,
I am subject to a wide range of legal and regulatory responsibilities which is not possible to list fully
here. I may be required by law or by regulators to provide personal
information, and in which case I
will have a legal responsibility
to do so. From time to time, clinicians
are unfortunately also the subject
of legal actions or complaints. In order
to fully investigate and respond to those
actions, it is necessary to access your personal information (although only to the
extent that it is necessary and relevant to the subject-matter).
44. Legal grounds:
a) The use is necessary in order
for us to comply with our legal obligations
45. Additional legal grounds
for special categories of personal information:
a) I need to use the data in
order for others to provide informed healthcare services to you
b) The use is necessary for reasons of the
provision of health or social care or
treatment or the management of health or social care systems
c) The use is necessary for establishing,
exercising or defending legal claims
Purpose 8: Managing my business
operations such as maintaining accounting records, analysis of financial
results, internal audit requirements, receiving professional advice (e.g. tax
or legal advice)
order to do this, I will not need to use your special categories of personal information
and so I have not identified the additional ground to use your i information for this purpose.
a) My having an appropriate business need to use
your information which does
not overly prejudice you
Disclosures to third parties:
48 I may disclose your information to the third parties
listed below for the purposes described in this
Privacy Notice. This might include:
a) A doctor or any other healthcare professional
involved in your treatment
b) Other members of support staff involved in
the delivery of your care, like receptionists and secretaries / practice
c) Anyone that you ask me to communicate with or
provide as an emergency contact, for example your next of kin or
d) NHS organisations
e) Other private sector healthcare providers
f) Your GP
g) Other clinicians (including their medical
h) Third parties who assist in the
administration of your healthcare, such as insurance companies
i) Government bodies, including the Ministry of
Defence, the Home Office and HMRC
j) Our regulators
k) The police and other third parties where
reasonably necessary for the prevention or detection of crime
l) Our insurers
m) I may also use your personal information to
provide you with information about products or services which may be
of interest to you where you have provided your consent for me to do
may communicate with these third parties in a variety of ways including, but not limited to, email, post,
fax and telephone.
How long do I keep your personal
will only keep your personal information for as long as reasonably necessary
to fulfil the relevant purposes set out in this Privacy Notice and in order to comply with my legal
and regulatory obligations
Consulting will hold information about you for as long as you receive services
from us and for 6 years following the date of our last contact with you.
52 Under data protection law you have certain rights in
relation to the personal information that I hold about you.
These include rights to know what information I hold about you and how
it is used. You may exercise these rights
at any time by contacting me using the details provided at section 3 above.
will not usually be a charge for handling a request to exercise your rights.
I cannot comply with your request to exercise your rights I will usually tell you
are some special rules about how these rights apply to health information
as set out in legislation including the Data Protection Act (current and future), the General Data
Protection Regulation as well as any secondary legislation
which regulates the use of personal information.
you make a large number of requests, or it is clear that it is not reasonable for me to comply with a
request, then we do not have to respond.
I can charge for responding.
The right to
access your personal information
57 You are usually entitled to a copy of the
personal information I hold about you and
details about how I use it.
58 Your information will usually be provided
to you in writing, unless otherwise requested. If you have made the request electronically
(e.g. by email) the information
will be provided to you by electronic means where possible.
59 Please note that in some cases I may not be
able to fully comply with your request,
for example if your request involves the personal data of another person and it would not
be fair to that person to provide it to you.
60 You are entitled to the following under
data protection law.
Article 15(1) of the GDPR I must usually confirm whether I have personal
information about you. If I do hold
personal information about you I usually need to explain to you:
purposes for which I use your personal information
ii. The types of personal information I hold
iii. Who your personal information has been or
will be shared with, including in particular organisations based outside the
iv. If your personal information leaves the EU,
how I will make sure that it is protected
v. Where possible, the length of time I expect
to hold your personal information. If
that is not possible, the criteria I use to determine how long I hold your
vi. If the personal data I hold about you was
not provided by you, details of the source of the information
vii. Whether I make any decisions about you
solely by computer and if so details of how those decision are made and the
impact they may have on you
viii. Your right to ask me to amend or delete
your personal information
ix. Your right to ask me to restrict how your
personal information is used or to object to my use of your personal
x. Your right to complain to the Information
need to provide you with a copy of your personal data, provided specific
exceptions and exemptions do not apply.
The right to
61 I take reasonable steps to ensure that the
information I hold about you is accurate and complete.
However, if you do not believe this is the case, you can ask me to update or amend it.
The right to erasure (also known as the
right to be forgotten)
may update this Privacy Notice from time to time to ensure that it remains accurate, and the most up-to-date version can always
be found on the Psynergy
website (www.psynergy.co.uk). In the event that there are any material changes to the manner in which
your personal information is to be used then I will provide you with an
updated copy of this Privacy Notice.
some circumstances, you have the right to request that I delete the personal information I hold about you. However, there are exceptions to this right and in certain circumstances I can refuse to
delete the information in question.
In particular, for example, I do not have to comply
with your request if it is necessary to keep your information in order to
perform tasks which are in the public interest, including public health, or for the purposes of
establishing, exercising or defending legal claims.
The right to restriction of processing
some circumstances, I must "pause" our use of your personal data if
you ask me to do so, although
I do not have to comply with all requests to restrict my use of your personal information. In particular, for example, I do not have to comply with your request if it is
necessary to keep your information in order to perform
tasks which are in the public interest, including public health, or for the purposes of establishing,
exercise or defending legal claims.
The right to data portability
some circumstances, I must transfer personal information that you have provided to you or (if this is
technically feasible) another individual or organisation of your choice. The information must be transferred in an electronic format.
The right to withdraw consent
some cases I may need your consent in order for my use of your personal information to comply with data
protection legislation. Where we do
this, you have the right
to withdraw your consent to further use of your personal information. You can do
this by contacting me using the details provided at section 3 above.
The right to complain to the Information
can complain to the Information Commissioner's Office if you are unhappy
with the way that I have dealt with a request from you to exercise any of these rights, or if
you think I have not complied with our legal obligations
information can be found on the Information Commissioner’s Office website:
69 Making a complaint
will not affect any other legal rights or remedies that you have.
Updates to this Privacy Notice
may update this Privacy Notice from time to time to ensure that it remains accurate. In the event that
these changes result in any material difference to the manner in which I process your personal data
then I will provide you with an updated copy of the Policy.
Privacy Notice was last updated on 20th May 2018
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