Privacy Policy Circle Psychology Partners Ltd and its associated service, Dulwich Psychologist, is a company offering clinical psychological and counselling services. This privacy policy explains how we use any personal information we collect about you or your child, as a past, present or future service user (client or patient) or when you use our website. 1. Who we are Circle Psychology Partners Ltd is registered with Companies House (Number 11159467). Circle Psychology Partners Ltd and its associated service, Dulwich Psychologist, deliver independent psychological therapy and counselling to children, adolescents and adults in our clinic rooms, outside of the therapy room during behavioural experiments or in the home of our clients. Circle Psychology Partners Ltd and Dulwich Psychologist is owned and directed by Dr Christine Langhoff, Clinical Psychologist, who is registered with the Health and Care Professions Council (HCPC). Circle Psychology Partners Ltd operates two websites at www.circlepsychologypartners.co.uk and www.dulwichpsychologist.co.uk  Circle Psychology Partners Ltd is committed to protecting the privacy of information provided by clients. 2. Data Control Dr Christine Langhoff is the data controller for Circle Psychology Partners Ltd and its associated service, Dulwich Psychologist. Circle Psychology Partners Ltd is registered with the Information Commissioners Office (ICO), registration reference: ZA328165, which can be searched for at: www.ico.org.uk Associate psychologists and associate counsellors taking on referrals with Circle Psychology Partners Ltd will be additional data controllers for the clients they work with directly and may have access to more data than Dr Langhoff due to the confidential nature of their therapy work with a specific client.  In such cases, associates will be the primary data controller for those clients. All our associates are registered with the ICO. 3. The lawful basis for processing personal data Circle Psychology Partners Ltd and Dulwich Psychologist have a legitimate interest in using the personal data and sensitive personal data we collect to provide health treatment; it is a requirement of our regulatory body, the Health and Care Professions Council. This ensures best practice care is achieved for our clients and is necessary for us to provide psychological therapy to clients.  We may also ask for information on how you found our service for the purpose of our own marketing research.  No information you provide is passed on without your consent.  We will never sell your information to others. 4. What information do we collect about you? When you/your child are/is a patient or client of Circle Psychology Partners Ltd or its associated service, Dulwich Psychologist, we record all your/your child’s treatment and details of your/their appointment so that your clinician can plan your/your child’s treatment correctly. Your/your child’s health record is kept confidential within the Circle Psychology Partners Ltd at all times and is only shared with staff when they need it to carry out their job. We collect information about you/your child that may include personal or sensitive information, such as: Personal data: basic contact information: name, address, date of birth, gender, email, contact telephone number, Skype ID (if online therapy), and GP contact details. Sensitive personal data: Signed Therapy Client Agreement, therapy records (therapist notes, letters, reports and/or outcome measures). Web-based data: If you complete a web-based enquiry form, we will also collect any information you provide to us as well as your internet protocol (IP) address.  This is automatically supplied by the website software used to offer the form.  All web services used by Circle Psychology Partners Ltd and Dulwich Psychologist are verified by themselves as GDPR compliant. Private Medical Insurance data: If you/your child are referred by a health insurance provider, then we will also collect and process personal data provided by that organisation. This includes basic contact information, referral information, and health insurance policy number and authorisation for psychological treatment. 5. What we do with your personal information At Circle Psychology Partners Ltd and Dulwich Psychologist we take your/your child’s privacy seriously. We will only use your personal information to provide the services you have requested from us. If you do not provide the personal information requested, then we may be unable to provide a therapy service to you. We use the information we collect to: - Provide our services to you/your child. - Process payment for such services. 6. How do we store the information about you? We are committed to taking reasonable steps to protect any individual identifying information that you/your child provide/s to us. Once we receive your/your child’s data, we make best efforts to ensure its security on our systems. All personal information provided is stored in compliance with EU General Data Protection Regulations (GDPR) rules.  7. How long we store personal information? We will only store your personal information for as long as it is required.  Basic contact information held on a therapist’s mobile phone is deleted within 6 months of the end of therapy. The sensitive personal data defined above is stored for a period of 7 years after the end of therapy. As children gain legal capacity when they turn 18 years old, we are required to keep their notes until they are 25 or 26 years of age (The Limitation Act, 1980). After this time, this data is deleted at the end of each calendar year. 8. Who we might share personal information with We hold information about each of our clients and the therapy they receive in confidence. This means that we will not normally share your/your child’s personal information with anyone else. However, there are exceptions to this when there may be need for liaison with other parties: If you/your child are/is referred by a health insurance provider, or otherwise claiming through a health insurance policy to fund therapy, then we will share appointment schedules with that organisation for the purposes of billing. We may also share information with that organisation to provide treatment updates. If you would like us to share information about your/your child’s treatment with outside organisations that are directly involved in your/your child’s care/case, for instance, your GP or psychiatrist, or your child’s school, we will require your written consent. We will tell you with whom we would discuss your/your child’s care, and what details we would share with them. In exceptional circumstances, we 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 the client, or risk of harm to another adult or a child. We will discuss such a proposed disclosure with you unless we believe that to do so could increase the level of risk to you or to someone else. 9. Your Rights Data protection legislation gives you/ the parent, various rights. The most important of these are as follows: • You have the right to a copy of information we hold about you/ your child. • You have the right to ask for your/ your child’s record to be amended if you believe that it is wrong. 10. How you can access your information and correct it, if necessary? Circle Psychology Partners Ltd and Dulwich Psychologist tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ or ‘Right of Access’ under the Data Protection Act and the General Data Protection Regulation. We will usually share this with you within 30 days of receiving a request. A copy of your personal information will usually be sent to you in a permanent form (that is, a printed copy). You have a right to get your personal information corrected if it is inaccurate. To make a request to Circle Psychology Partners Ltd for any personal information we may hold you need to put the request in writing. We may request further evidence from you to check your identity. We want to make sure that your/your child’s personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. Please address these changes to the Data Protection Officer, via “How to contact us”. 11. Complaints or queries Circle Psychology Partners Ltd and Dulwich Psychologist try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures. If you do have a complaint, contact the Data Protection Officer, Dr Langhoff, who will investigate the matter on your behalf. If you are not satisfied with the response from Circle Psychology Partners Ltd and Dulwich Psychologist, or believe we are not processing your personal data in accordance with the law you have the right to raise your complaint with the Information Commissioner’s Office (ICO) Contact information ICO: Website: https://ico.org.uk/concerns/ Email: casework@ico.org.uk Telephone: +44 (0) 303 123 1113 12. Other websites Our website contains links to other websites. Our privacy policy only applies to this website, we would encourage you to read the privacy statements on the other websites you visit. 13. Changes to this privacy notice We keep our privacy notice under regular review and we will place any updates on this web page. This privacy notice was last updated on 18th May 2018. 14. How to contact us Circle Psychology Partners Ltd and its associated service, Dulwich Psychologist, is the company that you are supplying your personal information to. The Data Protection Officer for Circle Psychology Partners Ltd and Dulwich Psychologist  is Dr Christine Langhoff and can be contacted by: Email: info@circlepsychologypartners.co.uk Post: 141 Woodwarde Road, Dulwich Village, London, SE22 8UP