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Privacy Notice

Contact details
Name: Luisa Sophie Frei
Address: 9 Fitzroy Place, Glasgow, G3 7RH
Phone Number: 07719 301207
E-mail: luisa.s.frei [at] protonmail.com

What type of information I have
I currently collect and process the following information:
• Name, address, DOB, phone number, email address, GP contact details, next of kin
• Session notes in both paper and electronic form, including any letters or assessment information
 • Billing information if required.

How I get the information and why I have it
Most of the personal information I hold is provided directly by you. With your written or verbal consent – and if clinically relevant – I may also receive information from outside sources of your choice (e.g. family, social work, your employer, etc). 
Under the General Data Protection Regulation (GDPR), the lawful basis I rely on for processing this information is legitimate interest.

What I do with the information I have
I use the information that you have given me in order to
• communicate with you,
• safeguard you and others,
• provide psychological treatment for you,
• write letters or reports you may request from me.

I hold information about each of my clients and the therapy they receive in confidence. This means that I will not normally share your personal information with anyone else. However, there are exceptions to this when there may be need for liaison with other parties:
• If you are referred by your health insurance provider, or otherwise claiming through a health insurance policy to fund therapy, then I will share appointment schedules with that organisation for the purposes of billing. I may also share information with that organisation to provide treatment updates.
• Every Clinical Psychologist is required to receive supervision. I may share anonymised information about you with my supervisor, who is in turn bound by the same confidentiality and data protection policy as I am.
• 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.

In exceptional circumstances, I might need to share personal information with relevant authorities:
• When there is need-to-know information for another health provider, such as your GP.
• When disclosure is in the public interest, to prevent a miscarriage of justice or where there is a legal duty, for example a Court Order.
• When the information concerns risk of harm to yourself, or risk of harm to another adult or a child. I will discuss such a proposed disclosure with you unless I believe that to do so could increase the level of risk to you or to someone else. 

How I store your information
Your information is securely stored in a locked filing cabinet in either my business or private premises. In transit, I will keep your information in a locked briefcase. Electronically, I will keep your information on password or fingerprint protected PCs, mobile phones or tablets. I may also use an online, electronic data management system, that uses encryption when uploading or downloading data. I use an encrypted email service.
I keep all your information for 7 years. I will then dispose of your information by permanently deleting electronic data or by shredding paper files. 

Your data protection rights
Under data protection law, you have rights including, but not limited to: Your right of access - You have the right to ask me for copies of your personal information.
Your right to rectification - You have the right to ask me to rectify information you think is inaccurate. You also have the right to ask me to complete information you think is incomplete.
Your right to data portability - You have the right to ask that I transfer the 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 Nurture Glasgow, 9 Fitzroy Place, Glasgow, G3 7RH, if you wish to make a request. 

How to complain
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 

Last updated in January 2020.

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