I, Dr Anna Butcher, am the data controller for my private psychology practice. I am registered with the Information Commissioners Office (ICO). This privacy notice tells you what to expect me to do with your personal information and covers the following:
Contact details
What information I collect, use, and why
Lawful bases and data protection rights
Where I get personal information from
How long I keep information
Who I share information with
How to complain
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Contact details
Dr Anna Butcher - Telephone: 07956 164013 Email: info@annabutcher.com
What information I collect, use, and why
If you make an enquiry to me about therapy or any other services I provide, I will hold any data you will have sent me voluntarily by email, text message or web enquiry form. If your enquiry goes no further than this initial contact, I will delete these data. If you and I go on to work together, I collect or use the following information to provide patient care and services:
- Name, address and contact details including telephone number and email address
- Date of birth
- GP/health professional details
- Emergency contact details
- If you are using private health insurance, I will hold your insurance policy number and authorisation code
- Therapy notes, any outcome measures completed, letters or reports written by or sent to health professionals or any other health provider concerning your treatment with me.
I also collect the following information to provide patient care and services:·
- Racial or ethnic origin
- Gender
- Health, personal history and background information
Lawful bases and data protection rights
Under UK data protection law, I must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website. Which lawful basis I rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website.
Your right of access - You have the right to ask me for copies of your personal information. You can request other information such as details about where I get personal information from and who I share personal information with. There are some exemptions which means you may not receive all the information you ask for.
Your right to rectification - You have the right to ask me to correct or delete personalinformation you think is inaccurate or incomplete.
Your right to erasure - You have theright to ask me to delete your personal information.
Your right to restriction of processing - You have the right to ask me to limit how we can use your personalinformation.
Your right to object to processing - You have the right to object to the processing of your personaldata.
Your right to data portability - You have the right to ask that I transfer the personal informationyou gave me to another organisation, or to you.
Your right to withdraw consent – When I use consent as my lawful basis you have the right towithdraw your consent at any time.
You can read more about these rights here: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/individual-rights/
Lawful bases for the collection and use of your data
My lawful bases for collecting or using personal information to provide patient care and services are:·
Consent - I have permission from you after I gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – I have to collect or use the information so we can enter into or carry out a contract together. All of your data protection rights may apply except the right to object.
Legal obligation – I have to collect or use your information so I can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interest - In order to understand and formulate a therapeutic plan of treatment for your mental health and wellbeing, your personal, social, biological and psychological circumstances are required to complete this. Details of emergency contacts are required in the event of risk or harm coming to you or your causing harm to others.
Vital interests - Collecting or using the information is needed when your physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Duty of confidentiality
I am subject to a common law duty of confidentiality. However, there are circumstances where I will share relevant health and care information. These are where:
- You’ve provided me with your consent (I have taken it as implied to provide you with care, or youhave given it explicitly for other uses);
- I have a legal requirement (including court orders) to collect, share or use the data;
- On a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
- If in England orWales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
- If in Scotland – I have the authority to share provided by the Chief Medical Officer for Scotland,the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.
- If I feel that you are a danger to yourself or to others, or if there is sufficient evidence to raise concern of the health, welfare or safety of children or vulnerable adults (please see my FAQs section for more details).
Please also note, on occasion my personal financial records (i.e. bank statements) may be required for certain legal financial procedures e.g. HMRC auditing or banking/borrowing processes. As such, some of your personal details will be on these records if you pay me directly by bank transfer i.e. your name or that of others with whom you may share an account. I will redact your personal details when records are submitted for these purposes as much as possible to protect your confidentiality; however, I cannot guarantee this will always be possible if I am required to provide documents that are unmodified/not edited. Under the ICO’s guidance of identifiers and what constitutes identifiability, however, it is important to note that your name alone may not be considered personal data if it is insufficient enough to identify you without other contextual data. Please visit the ICO’s guidance on this here if you wish to know more:https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/personal-information-what-is-it/what-is-personal-data/what-are-identifiers-and-related-factors/
How to complain
If you have any concerns about my use of your personal data, you can make a complaint to me using the contact details at the top of this privacy notice. If you remain unhappy with how I’ve used your data after raising a complaint with me, you can also complain to the ICO. The ICO’s address is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
This privacy policy is updated regularly in line with the ICO’s regulations as well as the guidance set out by my professional, statutory and regulatory bodies, the Health and Care Professions Council (HCPC) and the British Psychological Society (BPS). Please ensure you read this privacy policy along with the FAQs section about my practice. Weblinks for the relevant organisations can be found at the bottom of my website.
