Client Privacy Statement

This ‘Client Privacy Statement’ outlines how your personal data is processed during a discovery call, an assessment and therapy and coaching sessions.

This ‘Client Privacy Statement’ is separate to the ‘General Privacy Statement’ that can also be viewed on this website [coopoosamypsychology.com] from the footer of this website. The ‘General Privacy Statement’ applies to any data you may have shared or that we have collected via our website, social media profiles/pages or any third-party platforms we use. You can also view other relevant policies like the ‘Terms of Use’ and ‘Cookie Policy’ from the footer of this website.

All your personal data will be kept in accordance with the Data Protection Act (1998), General Data Protection Regulation (2018) and in line with Information Commissioners Office (ICO) guidance.

The type of personal information collected

Personal data

The following personal data is collected using the therapy/coaching agreement and intake forms, emails, referrals and during payment processing;

• Personal identifiers e.g. your name, dob, gender identity, preferred pronouns

• Contact data e.g. your email address, mobile number

• Payment details

• Private Medical Insurance (PMI’s) plan (for none self-funding clients only)

Special category data

Your data relating to your health is likely to be collected from referrals and during discovery calls, assessment sessions and any subsequent therapy or coaching sessions;

• Data concerning your health e.g. diagnoses, medication

The following personal data may be collected from referrals, the discovery call, during the assessment session and any subsequent therapy or coaching sessions;

• Personal data revealing your racial or ethnic origin

• Personal data revealing your religious or philosophical beliefs

• Data concerning your sex life

• Data concerning your sexual orientation

How the service collects personal information

Personal data

Your personal data will be collected in the following ways;

• Therapy/coaching agreement/intake forms

• Emails

• Bookings made using online

• Payment processors

• Correspondence with PMI’s (for none self-funding clients only)

• PMI platforms (for none self-funding clients only)

Special category data

Your personal data relating to your health may be collected in the following ways;

• Referrals

• Outcome measures e.g. questionnaires about how you are feeling

• Booking questions for discovery calls

• Discovery calls

• Assessment sessions

• Therapy or Coaching sessions

Your personal data relating to your racial or ethnic origin, your religious or philosophical beliefs, your sex life and your sexual orientation may be collected in the following ways;

• Discovery calls

• Assessment sessions

• Therapy or Coaching sessions

Why the service collects personal information

Personal data

Your personal data is collected for the following reasons;

• For the daily running of the service e.g. schedule session bookings

• To act as a record if there are any investigations or complaints in the future

• To ensure I can effectively manage risk and respond to any emergencies

• To be able to send you relevant and useful resources

• For invoicing and payment processing

• For book keeping and tax purposes

• For indemnity insurance and business insurance purposes

• To comply with relevant codes of conduct and legal obligations

• To comply with registration with Health and Care Professions Council (HCPC)

• To comply with PMI requirements (for none self-funding clients only)

Special category data

Your personal data relating to your health is collected for the following reasons;

• To ensure I have checked if I have the right expertise to address your health needs

• To ensure you have the best care and therapeutic input

• To ensure I can assess risk and safety in relation to your health needs

• To develop a suitable therapy/coaching plan

• To provide you with a more tailored psychological service

• To measure progress using outcome measures e.g. questionnaires on how you are feeling

You may be invited to discuss your experiences of intersectionality which may involve the collection of personal data on your racial or ethnic origin, your religious or philosophical beliefs, your sex life and your sexual orientation for the following reasons;

• Establish a  solid shared understanding your specific psychological and health needs

• To provide you with a more tailored psychological service

Please note that sharing this type of information is not required to access the services offered.

Who we share your personal information with

Personal data

Your personal data may be shared with;

• Referrers where relevant

• Relevant healthcare providers, safeguarding teams support services and medical professionals and GP’s where required. In such cases you would normally be consulted.

• A clinical supervisor where appropriate and using minimal personal data

• PMI’s for mainly checking authorised sessions, invoicing or funding requests

• Court of law if your clinical records are subpoenaed

Special category data

Your personal data related to your health may be shared with the following;

• Referrers where relevant

• Healthcare providers, safeguarding teams, support services and medical professionals and GP’s where required. In such cases you would normally be consulted.

• A clinical supervisor where appropriate and using minimal personal data

• PMI’s e.g. regarding funding for further sessions in relation to your health needs and progress in therapy and if they request a copy of your clinical records

• Court of law if your clinical records subpoenaed

Your personal data related to your racial or ethnic origin, your religious or philosophical beliefs, your sex life and your sexual orientation may be shared with;

• Healthcare providers, safeguarding teams, support services and medical professionals and GP’s but only where absolutely necessary. In such cases you would normally be consulted.

• A clinical supervisor where appropriate and using minimal personal data

• Court of law if your clinical records are subpoenaed

Lawful base:

Under the General Data Protection Regulation (GDPR) we rely on the following lawful bases to process your personal data, including special category data:

• Consent

• Contract

• Legal obligations

• Legitimate Interests

You are able to withdraw your consent at any time. You can do this by contacting [Dr Yvanna Coopoosamy by email: yvanna.psychology@protonmail.com]. All sessions will cease and no further personal  or special category data will be collected or recorded. Then the withdrawal of consent and category of data withdrawn will be noted.

How we store your personal information

Your personal data (excluding any special category data) is stored on one or more of the following third-party platforms; a secure email account (Protonmail), a client booking platform (Calendly), an invoicing platform (Healthcode), PMI platforms (AXA, BUPA, AVIVA), a payment processor (Square), video conferencing tools (Microsoft Teams, Zoom) and encrypted hard drives, stored securely.

Clinical records which include your personal data and any special category data is stored in a GDPR compliant, encrypted clinical record platform (Write-upp) only, which is specifically designed for keeping clinical records.

Third-party platforms

Your personal data may need to be shared with a third-party in the event that Dr Yvanna Coopoosamy is no longer able to offer a service. However this will be managed on a strict need-to-know basis and you will be informed of the management of your personal data and informed of your options in relation to your personal data if this occurs.

Use of the following third-party platforms; Protonmail, Calendly, Healthcode, AXA, BUPA and AVIVA platforms, Square, Microsoft Teams, Zoom and Write-upp may involve the transfer of your personal information and any special category information outside the European Economic Area (EEA) where they are based outside of the EEA. However, use of third-party platforms that store information outside of the EEA is kept to a minimum and the chosen third-party platforms used are carefully selected to provide a sufficient level of protection for the processing and storage of your data.

If it is necessary to share your personal data with a third-party such as a healthcare providers, safeguarding teams, support services, medical professionals, GP’s and PMI’s you would normally be consulted first and the sharing of your personal data will only be completed using a secure email account, an encryption system or secure document sharing system.

Your data protection rights

Under data protection law, you have rights including:

• Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

• Your right to access - You have the right to ask us for copies of your personal information (commonly known as a "data subject access request"). This right always applies. There are some exemptions, which means you may not always receive all the information we process.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at [info.coopoosamypsychology@protonmail.com] if you wish to make a request. You can see more information on your data protection rights on the ICO website (see link below):

https://ico.org.uk/global/privacy-notice/your-data-protection-rights/

How long the service keeps your data

• Your personal data that you share in a discovery call is securely destroyed if we are not able to provide a service to you, or you decide you do not wish to access our service(s) and once we have dealt with you query and provided any signposting or onwards referrals and informed your referrer that you will not be seen in the service, if relevant.

• Your personal data that you share in a discovery call will be transferred  to a GDPR compliant, encrypted database called Write-upp which is specifically designed for clinical records and an encrypted hard drive stored securely if we agree for you to access an assessment session and any therapy or coaching sessions.

• If you access therapy or coaching services after an assessment session or disclose a safeguarding risk (even if you do not access therapy or coaching sessions) your personal data will be retained for 7 years, after which it is securely destroyed.

Other information

• The therapy/coaching agreement/intake forms include clear opt-in or opt-out options for email reminders for booked sessions

• Feedback forms used to improve the service do not require the inclusion of your personal data and any testimonials used for advertising are separated from your personal data

• Video calls used  for online therapy and coaching sessions will never be recorded

How to complain

If you have any concerns about the use of your personal data you can make a complaint to [Dr Yvanna Coopoosamy by email: info.coopoosamypsychology@protonmail.com].

You can also complain to the ICO if you are unhappy with how we have used your personal 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

Changes to this statement

We may update this ‘Client Privacy Statement’ from time to time and we will notify you of these via a pop-up announcement on this website.

Thank you for taking the time to read this statement.