Expert Psychologists Limited – UK GDPR Privacy Notice

(1) SCOPE

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.  

The UK General Data Protection Regulation (UK GDPR) and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of UK data subjects.

These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.

(2) WHO WE ARE

For the purposes of this “Privacy Policy” Expert Psychologists Ltd is based at Expert Psychologists Ltd, School House, Mill Lane, Kemberton, Shifnal, Shropshire TF11 9LH, which hereafter for the purposes of this “Privacy Policy” will be referred to as “Expert Psychologists”, offering psychological services in accordance with the British Psychological Society’s standards and guidelines https://www.bps.org.uk/psychologists/standards-and-guidelines

(3) WHAT IS THIS POLICY FOR

This Privacy Information explains how Expert Psychologists practices, controls, processes, and protects all personal information, including details on how personal information is used in the day-to-day running of Expert Psychologists, including your rights under current laws and regulations.  

It applies to the following:

• Members of the public contacting Experts Psychologists by phone, text, email or by post,

• Employees, staff and professional colleagues of Expert Psychologists,

• Recipients of psychological services; and

• Members of the public browsing or using this website.

(4) RESPONSIBILITY FOR DATA PROTECTION

For the purposes of data protection legislation, The ‘Data Controller’ is Dr Loumidis, Director of Expert Psychologists Ltd, (ICO Registration Number Z9737627).

Expert Psychologists Ltd have appointed Dr K. Loumidis, the Director of Expert Psychologists as “Privacy and Compliance Officer” who will deal with all your requests and enquiries concerning the use of your personal data and try  to ensure that all personal data is processed in compliance with this policy and data protection law.

(5) WHAT IS PERSONAL INFORMATION

Personal data is defined by the The UK General Data Protection Regulation (UK GDPR) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

(6) CATEGORIES OF INFORMATION

We process two categories of information about you and (where this applies) your dependants:

• Standard Personal Information which helps us to contact, identify or manage our relationship with you; and

• Special Categories of information, which helps us to tailor your care.

(7) STANDARD PERSONAL INFORMATION

Standard Personal information includes:

• contact information such as name, address, phone numbers and email address;

• the country you live in, age, date of birth and national identifiers such as passport document or National Insurance number, employment details, details of any contact we had with you such as any complaints or incidents, financial details which if required, we store your card details on our secure Sage Pay service for 90 days, which are then deleted.

(8) SPECIAL CATEGORY INFORMATION

Special Category information includes:

• information about your physical or mental health, from notes and reports about your health and any treatment and care you have received or need, or it may be recorded in details of contact we have had with you such as information about complaints or incidents, and referrals from your existing insurance provider, quotes and records of medical services you have received);

• information about your race, ethnic origin and religion (we may get this information from your medical preferences to allow us to provide care that is tailored to your needs); and

• information about any criminal convictions and offences (we may get this information when carrying out anti-fraud or anti-money-laundering checks, or other background screening activity

(9) HOW WE COLLECT PERSONAL INFORMATION

We collect personal information from you and from third parties (anyone acting on your behalf, for example, solicitor, personal injury services, insurers etc.).

We collect personal information from you through your contact with us via phone email, our website or by post.

We also collect information from other people and organisations.

We collect information from

• solicitors, rehabilitation agencies or indirectly from documents provided by them, including reports from expert witnesses.

We may collect information from

• a family member or someone acting on your behalf;

• doctors, clinicians, health care professionals, hospitals, clinics, and other health care providers; and

• any service providers who work with us in relation to your service.

If we provide you with health care, we may collect information from

• your employer,

• your parent or guardian (if you’re under 18 years old),

• those paying for the products or services we provide to you including other insurers.

(10) WHAT WE USE YOUR INFORMATION FOR

Confidentiality and consent to treatment are core values of our professional practice and we provide a professional psychological service.  

Any information disclosed will be treated with respect and will be confidential, unless he has serious professional or ethical reasons for not doing so, in which case he will discuss this matter with you.

We use your personal information only for “legitimate interest purposes” set out in this privacy notice.

We process standard personal information about you if this is necessary to provide the services set out in a contract, if this is in our or a third party’s legitimate interest, or if this is required or allowed by law.

We process special category information about you because:

• it is necessary for the purposes of health prevention, assessment and treatment services;

• it is necessary for insurance purposes;

• it is necessary to establish, make or defend legal claims;

• it is preventing or detecting an unlawful act, malpractice, dishonesty or other serious improper behaviour;

• it is in the public interest;

• in line with any laws apply;

• it is information that you have made public; or/and

• because we have your permission.

(11) LEGITIMATE INTEREST PURPOSES

Expert Psychologists will only collect the information needed so that we can provide you with the services you require.  

The business does not sell, broker, outsource of make any profit from your data.

For administrative purposes

• For the purposes of booking an appointment, all patients will need to provide personal information, including their title, name, surname, date of birth, address, telephone number, mobile number email address, name of GP, name in insurer (if insured) and financial details.

• Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports or other information concerning your treatment.

For financial and accounting purposes

You will be required to provide written consent for Expert Psychologists to contact your insurers, send invoices to your insurers or to any other third parties paying for your fees.

You will need to provide card details before the first appointment, and a signed form, to take future payments, unless your fees are paid by others. Separately, Spire and Nuffield Hospital policies also require that you give them these details.

For psychological purposes

During the consultation, psychologists elicit detailed personal, medical, and other psychologically relevant information. We will only collect what is relevant and necessary for your treatment.

This data is always held securely, is not shared with anyone not involved in your treatment, although for data storage purposes it may be handled by administrative staff who have all signed an integrity and confidentiality agreement.

To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow psychologists to document and process your personal medical data.

For marketing purposes

Expert Psychologists does not use any of your information.  Expert Psychologists will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data.

For expert witness purposes

If your solicitors have referred you for an independent psychological report for the Court, you will be examined by a psychologist acting as an independent expert witness and not for confidential treatment purposes.  

The psychologist’s duty is to the Court and not the claimant, defendant, or any instructing parties. The report will contain an independent, unbiased opinion negotiable only in respect of basic factual detail, although the solicitors may request clarifications.  

Copies of the report may be sent to third parties, solicitors or indeed may be presented in Court and the usual principles of confidentiality between a patient and a psychologist cannot be presumed in that instance.

For other business related purposes

Expert Psychologists may use information for the following purposes:

• to help manage our relationship with you, our business and third parties who provides products or services for us;

• to provide health care service on your behalf of a third party;

• to investigate complaints and incidents;

• for statistical research and analysis so that we can monitor and improve our products and services;

• to monitor our clinical and non-clinical performance expectations;

• to enforce or apply our website terms of use, our policy terms and conditions or other contracts, or to protect our (or our customers’ or other people’s) rights, property or safety;

• to exercise our rights, to defend ourselves from claims and to keep to laws and regulations that apply to us and the third parties we work with;

• or to take part in, or be the subject of, any sale, purchase, merger or takeover of all or part of the Expert Psychologists business.

(12) CONSENT

Before you see Dr Loumidis, you will be provided with relevant Terms and Conditions, which you will be requested to read, consent to and sign.

By visiting the website you are agreeing to this privacy notice and consenting to Expert Psychologists processing your personal data for the purposes outlined.

You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.

(13) DISCLOSURE

Summary

Expert Psychologists will keep your personal information safe and secure, and only staff engaged in providing your treatment will have access to your patient records, although our administration team will have access to your contact details so that they can make appointments and manage your account.

Expert Psychologists will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests.

Expert Psychologists may also enforce its Terms and Conditions, including:

• investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or

• to protect against imminent harm to the rights, property, or safety of its staff.

General principles of data sharing

With your consent, we share information with:

• doctors, clinicians and other health-care professionals, hospitals, clinics and other health-care providers;

• suppliers who help deliver products or services on our behalf;

• people or organisations we have to, or are allowed to, share your personal information with by law (for example, for fraud-prevention or safeguarding purposes);

• the police and other law-enforcement agencies to help them perform their duties, or with others if we have to do this by law or under a court order;

• if Expert Psychologists sell or buy any business or assets, the potential buyer or seller of that business or those assets;

• if we provide you with health care, with your consent we share information with your employer, if your employer is paying for the services we are providing;

• our insurance partners, for example, solicitors and interpreters;

• those paying for the products or services we provide to you; or

• other clinicians those providing your treatment.

Data for booking appointments

This information contains your name, contact details, address, name of GP, who pays for treatment and your email.  

This is sent to the receptionist of the consulting rooms or the private hospital where your appointment will be held.

Data for insured members

We are recognised by major insurers such as Alliance, Aviva, AXA, Bupa, Cigna, PruHealth, Simply Health, Vitality, and WPA, as well as other agencies.  

An invoice will contain your name, contact details, address, pre-authorisation number and sometimes your condition.

Data for rehabilitation patients

With your explicit consent we will send an initial assessment report, progress reports, and an end of treatment report to the rehabilitation agency, who will then share this with the party paying for your fees.  

This information contains your name, contact details, address, name of your GP, who pays for treatment, your email and clinically sensitive information.

Limits of confidentiality

You must confirm that you understand that Dr Loumidis does not operate an emergency or out-of-hours crisis service. In an emergency, if you (or others) feel that you could be a risk to yourself or others, you will need to contact your GP, 999 or your local A&E.  

You must confirm that you understand that all sessions are confidential, unless there is a serious risk of harm or neglect to yourself or others. If so, Dr Loumidis may need to talk to other professionals without your consent.

Data for expert witness services

In expert witness work, the role of the psychologist is to assess people an independent expert witness and not for the provision of any private and confidential psychological assessment or treatment services.

The assessment will include in detail and in depth, both post-incident as well as pre-incident circumstances.  It is important that you provide Dr Loumidis with a complete and accurate history, without concealing or minimising the significance of any of your circumstances.

Copies of the report will be sent to third parties, and/or the Court/Tribunal and the usual patient-psychologist therapeutic confidentiality does not apply.

Data used in supervision

All psychologists, irrespective of grade, undertake professional supervision, and you will need to confirm whether, with your consent, you agree for Dr Loumidis to anonymously discuss your cases with other professionals.

Data used in clinical correspondence

With your consent Dr Loumidis will be sending a letter outlining in detail the content of the assessment, his opinion, your treatment plan, and regular updates to your referrer, GP, any professionals involved in your care, or your insurer (if requested).

With your consent Dr Loumidis will copy you into any correspondence about your care. With your consent Dr Loumidis will be using your details as provided by you, for letters or any correspondence.

(14) RETENTION

Expert Psychologists will process personal data during the duration of any treatment and will continue to store only the personal data needed to meet any professional and/or legal obligations.

After seven years all personal data will be deleted, unless basic information needs to be retained by us to meet our future obligations to you, such as erasure details.

(15) DATA STORAGE

All Data is held in the United Kingdom. Expert Psychologists does not store personal data outside the EEA.

All data storage services used by Expert Psychologists are fully GDPR compliant and available on request.

(16) LEGAL BASIS FOR PROCESSING ANY PERSONAL DATA

To meet our contractual obligations obtained from explicit Patient Consent and legitimate interest to respond to enquiries concerning the services provided.

(17) YOUR RIGHTS AS A DATA SUBJECT

At any point whilst Expert Psychologists is in possession of, or processing your personal data, all data subjects have the following rights:

Right of access

You have the right to request a copy of the information that we hold about you.

Right of rectification

You have a right to correct data that we hold about you that is inaccurate or incomplete.

Right to be forgotten

In certain circumstances you can ask for the data we hold about you to be erased from our records.

Right to restriction of processing

Where certain conditions apply you have a right to restrict the processing.

Right of portability

You have the right to have the data we hold about you transferred to another organisation.

Right to object

You have the right to object to certain types of processing such as direct marketing, but this does not apply here because we do not engage in any direct marketing.

Right to object to automated processing, including profiling

You also have the right not to be subject to the legal effects of automated processing or profiling.

Limitation

In the event that Expert Psychologists refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.

At your request Expert Psychologists can confirm what information it holds about you and how it is processed.

(18) HOSTING OF DATA

The website is hosted by https://blacklight-studio.co.uk

(19) YOU CAN REQUEST THE FOLLOWING INFORMATION

You can request the following information:

• Identity and the contact details of the person or organisation (Expert Psychologists) that has determined how and why to process your data.

• Contact details of the data protection officer, where applicable.  The purpose of the processing as well as the legal basis for processing.

• If the processing is based on the legitimate interests of Expert Psychologists and information about these interests.

• The categories of personal data collected, stored and processed.

• Recipient(s) or categories of recipients that the data is/will be disclosed to.

• How long the data will be stored.

• Details of your rights to correct, erasure, restrict or object to such processing.

• Information about your right to withdraw consent at any time.

• How to lodge a complaint with the supervisory authority (ICO).

• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.

• The source of personal data if it was not collected directly from you.

• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

(20) CLINICAL RESEARCH AND STATISTICAL PURPOSES

We do not collect or use information for clinical research and statistical purposes.

(21) DATA SECURITY AND PROTECTION

We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information.

Our methods meet the GDPR compliance requirement.

(22) INTERNET COOKIES

We do not use cookies.

(23) HOW CAN ACCESS YOUR PERSONAL DATA

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “Subject Access Request”.

Subject Access Request

All subject access requests should be made in writing and sent to the email or postal addresses shown.  

If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) further fees may be charged to cover our administrative costs in responding.  

We will respond to your subject access request within without undue delay and at the latest within one calendar month.

Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of progress.

Limitations

In some cases, where you are involved in litigation and access to your data may undermine a medico legal case it may be necessary to inform the solicitors and the Court involved in the case, and their approval sought, before such data can be provided.

Claimants should note that in a medico legal case the solicitor requesting the assessment (and ultimately the Court) is also the data controller in a legal case and therefore a subject access request may have to be made to more than Expert Psychologists Ltd for access to the data it holds on you and may be denied by the solicitor or the Court if access to that data, at that time, may undermine a legal case.

(24) WHAT WE NEED BEFORE YOU CAN ACCESS YOUR PERSONAL DATA

To access what personal data is held, identification will be required.  Expert Psychologists will accept the following forms of identification (ID) when information on your personal data is requested:

• A copy of your driving licence, passport, or birth certificate, together with a utility bill not older than three months.

• A minimum of one piece of photographic ID listed above and a supporting document is required.

If Expert Psychologists is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made by email via the website, or by phoning 07738 559 114, or by writing to us at Expert Psychologists Ltd, School House, Mill Lane, Kemberton, Shifnal, Shropshire TF11 9LH. If you do not hear back from us within five days please try another form of contact.

(25) COMPLAINTS

In the event that you wish to make a complaint about how your personal data is being processed by Expert Psychologists, you have a statutory right to raise your data protection complaint directly with us in the first instance.  We will acknowledge your request and aim to respond without undue delay.

If you remain dissatisfied with our response, you have the right to lodge a formal complaint with the Information Commissioner’s Office (ICO).

The details for each of these contacts are:

• Dr Loumidis, Director of Expert Psychologists Ltd, School House, Mill Lane, Kemberton, Shifnal, Shropshire TF11 9LH

• Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF Telephone +44 (0) 303 123 1113 https://ico.org.uk

(26) UPDATED VERSION

We may change this policy from time to time by updating this page.

You should check this page from time to time to ensure that you are happy with any changes.