OVERVIEW
1. Important information and who I am
2. The data we collect about you
3. How is your personal data collected?
4. How I use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Glossary
Introduction
Welcome to Dr Storek’s privacy notice.
I respect your privacy and that of your child. I am committed to protecting both your personal data and that of your child – Hereinafter whenever I refer your personal data, I will also mean that of any child for whom you have parental responsibility or for whom you act in loco parentis and bring to me for assessments. This privacy notice will inform you as to how I look after your personal data when you contract me for psychological assessments and consulting services and tell you about your privacy rights and how the law protects you.
I have provided a Glossary to help you understand the meaning of some of the terms used in this privacy notice.
1. Important information and who I am
Purpose of this privacy notice
This privacy notice aims to give you information on how I collect and process your personal data, including any data you may provide me.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice I may provide on specific occasions when I am collecting or processing personal data about you so that you are fully aware of how and why I am using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
I am the controller and responsible for your personal data.
I am responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise them, please contact me using the details set out below.
Contact details
My full details are:
Dr Josephine Storek
122 Beaufort Street
London SW3 6BU
Kensingtonpractice@gmail.com
Changes to the privacy notice and your duty to inform me of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
I may collect, use, store and transfer different kinds of personal data (“Aggregated Data”) about you and your child which I have grouped together follows:
· Identity Data includes first name, last name, title, date of birth and gender.
· Contact Data includes address, email address and telephone numbers.
· Assessment Data includes psychological and educational assessment data, including parental input, medical history, academic work product, teacher and tutor assessments as provided to us by you or by schools.
· Transaction Data includes data about what services you have received from me.
I also collect, use and share Aggregated Data such as statistical or demographic data for medical research purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, I may aggregate your data to calculate the percentage of users affected my certain medical conditions or discuss how certain illnesses are correlated with others. However, if I combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, I treat the combined data as personal data which will be used in accordance with this privacy notice.
I also collect Special Categories of Personal Data about you (this includes details about your religious preferences relating to school searching, and information about your mental, physical and psychological health (and that of your immediate and extended familiy). I do not collect any information about criminal convictions and offences.
3. How is your personal data collected?
I use different methods to collect data from and about you including through:
· Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
· Fill in our intake data form;
· Answer any electronic or paper questions;
· Academic work samples provided by you; and
· Through interviews with you and your child.
· Third parties. I may receive personal data about you and your child from various third parties as set out below:
· You or your child’s school or teacher;
· You or your child’s GP;
· You or your child’s psychiatrist;
· Your childcarer or nanny;
· Other persons with parental responsibility of your child; and
· Your or your child’s tutor.
4. How I use your personal data
I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:
· Where I need to perform the contract I am about to enter into or have entered into with you.
· Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where I need to comply with a legal or regulatory obligation.
I do not rely on consent as a legal basis for processing your personal data. I do not send your personal data to any third party.
Purposes for which I use your personal data
I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what our legitimate interests are where appropriate.
Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact me if you need details about the specific legal ground I am relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a new client |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To process and deliver services to you including: (a) Deliver reports and psychological assessments to you (b) Manage payments, fees and charges (c) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Assessment (d) Transaction |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Providing with you additional information as it becomes available from time to time that is relevant to you or your child |
(a) Identity (b) Contact (c) Assessment (d) Transaction |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
5. Disclosures of your personal data
We share your personal data with Pearson clinical for generate reports from psychological measures based on your questionnaires.
6. International transfers
I do not transfer your personal data outside the European Economic Area (EEA).
7. Data security
I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, I limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any medical, legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, I consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
I may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up my response.
Time limit to respond
I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that I am subject to.
THIRD PARTIES
· Service providers acting as processors based who provide IT and system administration services.
· Pearson Clinical who provide medical and psychological services.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data I hold about you and to check that I am lawfully processing it.
Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to me.
Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. Note, however, that I may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios: (a) if you want me to establish the data’s accuracy; or (b) where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) with respect to data protection issues.