Privacy Notice
A privacy notice is a document that explains to parents and young people how I collect, use, retain, disclose, and protect their personal data.
1. Website data and analyitics:
This website is hosted by Squarespace. Squarespace collects personal data when you visit this website, including:
Information about your browser, network and device
Web pages you visited prior to coming to this website
Web pages you view while on this website
Your IP address
Squarespace needs the data to run this website, and to protect and improve its platform and services. Squarespace analyzes the data in a de-personalized form.
This website collects personal data to power our site analytics, including:
Information about your browser, network, and device
Web pages you visited prior to coming to this website
Your IP address
This information may also include details about your use of this website, including:
Clicks
Internal links
Pages visited
Scrolling
Searches
Timestamps
I share this information with Squarespace, our website analytics provider, to learn about site traffic and activity.
When you submit information to this website via webform, I collect the data requested in the webform in order to track and respond to your submissions. I share this information with Squarespace, my online store hosting provider, so that they can provide website services to me. I also share this information with google mail for storage.
This website serves font files from and renders fonts using Google Fonts and Adobe Fonts. To properly display this site to you, these third parties may receive personal information about you, including:
Information about your browser, network, or device
Information about this site and the page you’re viewing on it
Your IP address
2. The type of information I may process:
I process personal information to enable me to provide psychological services to my clients, to maintain accounts and records, to promote services, and comply with legal obligations. This personal information may include:
Your name
Home address
Email Address
Telephone Number
Video Chat Username
Educational history
Employment history
I may also process sensitive information as part of a psychological assessment that may include:
medical records
psychometric test data
sexuality
racial or ethnic origin
religious or other beliefs of a similar nature
criminal offences and alleged offence
3. How I collect this information:
Information provided by you:
Most of the personal information I collect is given to me directly by you when:
Making an enquiry, either over the phone or by email
Completing the consent and information form prior to an appointment
Attending a consultation or therapy session
Completing psychological forms or tests
Information from a third party:
I may be provided information about you or your child by other people or organisations if it is relevant to the service being provided. You will be asked for consent before I contact other people to collect more information about you or your child. Such organisations and people may include:
A school, college, or university
A local authoriy
A social worker
NHS services (including CAMHS, SALT, Child Development Centre, GP)
Police
4. Lawful basis for collecting information:
Under the General Data Protection Regulation (GDPR), the lawful bases I rely on for processing this information is:
Unambiguous consent.
This means:
you have given specific, unambiguous consent for me to process data given within about you and/or your child.
Through reading this privacy notice, the consent form and “What is an EP?” document (provided as part of the consent process) you understand that I will be working with your your child and processing their data and give me consent to do so.
You are able to withdraw your consent at any point for me to process your or your child’s data.
Children who are Gillick competent must give their own consent (this is generally deemed to be considered on a case by case basis when children reach 12 years of age)
Children who are not deemed to be Gillick competent (under 12) must have consent provided through those who hold parental responsibility.
I will keep documentary evidence of consent (e.g. the signed consent form).
5. How I use the information:
I will use the information I collect to:
Communicate with you about your enquiry or appointment.
Communicate with people or organisations you have asked me to contact, who are relevant to your enquiry.
Offer you an appropriate service.
Carry out a psychological assessment or provide therapy.
Write a psychological report.
Facilitate invoicing, payment, and financial auditing.
6. Who I would share the information with:
I share your information routinely with the following organisations as part of providing a service to you or helping with your enquiry:
The school your child is attending (In particular if this school has asked for and is commissioning this assessment)
SITUATION-SPECIFIC SHARING
If you have asked me to, or where I am required to by law, I will share information about you with the following people or organisations where necessary.
A school, college, or university
A local authority
A social worker
NHS services (e.g. CAMHS, SALT, CDC, GP)
A family member
Police
7. How long do I keep information for?
Situation: An inquirer who decides they do not require educational psychologist involvement from me
Time frame: 6 months
Reason: I allow a reasonable amount of time for clients to consider their options before deleting enquiry records. A proportion of enquirers do not return for a service within 6 months of initially speaking with me
Situation: Psychological assessment
Time frame: Until the child/young person turns 25
Reason: This ensures the child/Young person has time to retrieve their records later as an adult and ensures I can fulfil my obligations to any potential future legal matters.
Situation: Payment records
Timeframe: 7 years
Reason: This fulfils my requirements for financial auditing.
8. How is your information disposed of?
After the retention period, your information is disposed of in one of two ways:
The majority of my records are digital. However on the rare occasions I receive paper copies these are shredded and securely disposed of
For digital records held on my device or encrypted drives, the record is deleted and ‘wiped’ with random data to render it irretrievable
9. How is your information kept safe:
My guiding principle is that I am holding your and your child’s information in strict confidence. I am registered with the Information Commissioners Office (ICO). You can enter my registration number at: ZB195566. https://ico.org.uk/esdwebpages/search and click ‘search register’.
I keep your information safe in the following ways:
Only I have access to your data on my systems
Your digital information is encrypted with a password while kept in my systems
Any reports and documents send to you via email are password encrypted
My devices are checked frequently for malware and I have use to date antivirus software
Paper records are kept in a locked storage area.
Documents that are no longer needed are securely collected and destroyed.
10. Your data protection rights
Under data protection law, you have rights including:
Your right of access - You have the right to ask me for copies of your and your child’s personal information.
Your right to rectification - You have the right to ask me to rectify personal information you think is inaccurate. You also have the right to ask me to complete information you think is incomplete.
Your right to erasure - You have the right to ask me to erase your and your child’s personal information in certain circumstances. For example, if you have made an enquiry but did not go ahead with a psychological assessment, your enquiry information can be deleted. Assessment records must be kept in-line with the information in section 6 of this policy.
Your right to restriction of processing - You have the right to ask me to restrict the processing of your and your child’s personal information in certain circumstances.
Your right to object to processing - You have the right to object to the processing of your or your child’s personal information in certain circumstances.
Your right to data portability - You have the right to ask that I transfer the personal information you gave me to another organisation, or to you, in certain circumstances
You are not required to pay any charge for exercising your rights.
If you make a request, I have one month to respond to you. Please contact me at NDHPsychology@protonmail.com if you wish to make a request.
11. Your right to complain:
If you have any concerns about my use of your or your child’s personal information, you can make a complaint to me at NDHPsychology@protonmail.com. You can also complain to the ICO if you are unhappy with how I have used your data. The ICO’s address: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Helpline number: 0303 123 1113 ICO website: https://www.ico.org.uk