Claire Wilson Consulting Limited (CWC) is a company offering clinical psychological services (including psychological assessment, therapy and court related work). This privacy policy explains how we use any personal information we collect about you, as a past, present, future employee, a service user (client or patient) or when you use our website. We are registered with the Information Commissioner’s Office (ICO) and have updated this policy following the new GDPR guidance which comes into effect on 25th May 2018.

Your rights under the new General Data Protection Regulation:

The GDPR includes the following rights for individuals:

  • the right to be informed;
  • the right of access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to data portability;
  • the right to object; and
  • the right not to be subject to automated decision-making including profiling.

We have responsibilities to think about these rights and how we can safely deliver psychological services whilst still meeting these requirements. The following document aims to explain these but if you want to know more please get in touch.

  1. Why do we collect at information about you?

We have a number of lawful reasons that we can use (or ‘process’) your personal information. One of the lawful reasons is called ‘legitimate interests’.

Broadly speaking Legitimate Interests means that we can process your personal information if:

  • We have a genuine and legitimate reason and we are not harming any of your rights and interests

So, what does this mean? When you provide your personal details to us we use your information for our legitimate business interests. Before doing this, though, we will also carefully consider and balance any potential impact on you and your rights.

  1. What information do we collect about you?

We collect information about you that may include personal or sensitive information, such as:

  • First name or given name
  • Family name or surname
  • Address
  • Telephone numbers
  • Date of birth
  • Gender (or preferred identity).
  • Age.
  • Date of Birth.
  • Relationships & children
  • Occupation.
  • Address.
  • Telephone/SMS number
  • Email address

To make sure that you are assessed and/or treated safely, we record your personal information, such as your name, address, as well as all contacts you have with the Company such as appointments and the results of assessments and letters relating to your care/report. Your health record is kept confidential within the Company at all times and is only shared with staff when they need it to carry out their job.

Patients/Clients (Therapy or private assessment)

When you are a patient or client of Claire Wilson Consulting we record all your treatment and details of your appointment so that your clinician can plan your treatment correctly. In addition to the personal information above, we may also collect information regarding:

  • Medical conditions (if relevant)
  • Prescribed medication.
  • Psychological history and current difficulties.
  • Sexuality
  • Offences (including alleged offences)
  • Financial information, including bank account details (if you are a private patient/client of Claire Wilson Consulting)

Clients undertaking Court Reports

In the case of a court report we retain the information as required by the courts or your solicitor.

In addition to the personal information above, we may also collect information regarding:

  • Medical conditions (if relevant)
  • Prescribed medication.
  • Psychological history and current difficulties.
  • Sexuality
  • Offences (including alleged offences)

Job applicants, current and former CWC employees and associates

When individuals apply to work at Claire Wilson Consulting, we will only use the information you supply to us to process your application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Disclosure and Barring Service we will not do so without informing you beforehand unless the disclosure is required by law.

Web access collection of information

We collect information about you when you register with us or place any order for services. We also collect information when you voluntarily complete contact forms. Claire Wilson Consulting always tries to minimise the amount of personal information that we require in order to provide a specific service or feature.

  1. How do we store the information about you?

We take your privacy very seriously.

We are committed to taking reasonable steps to protect any individual identifying information that you provide to us. Once we receive your 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.

Our IT policy is as follows:

Personal information or any sensitive information is only sent by password protected files to people involved in your care, whom you have given permission to be involved. We have recently moved to a system of sending secure electronic links rather than attachments using a GDPR compliant cloud system. Where attachments are needed and contain any personal information the attachment will be password protected.

Any reports or notes are also stored electronically on a GDPR compliant secure system. Any paper notes are kept in a locking filing system at the office of Claire Wilson Consulting Limited. Access to these records is limited to staff at Claire Wilson Consulting Limited who all adhere to a confidentiality policy and only access information needed to provide your care or support in the case of therapeutic services or in the administrative aspects of court report writing. We adhere to professional policies on how long to retain that information – we are legally required to keep hold of such data for a set period of time. After this time your data will be electronically shredded.

Laptops/tablets and mobile phones are password protected and passwords changed regularly (other than tablet which has finger print technology). Full names are not stored in contacts (first name and first initial of last name) and at the end of therapy these will be deleted. No one else in CWC has access to the electronic devices. Any information is stored within a GDPR compliant system not on the hard drive of the laptop or tablet.

  1. How long do we keep your information for?

Patients/Clients (Therapy or private assessment)

We will retain your information as set out in the NHS Code of Practice for Records Management (Records Management Code of Practice for Health and Social Care 2016).

Clients undertaking Court Reports

If your case is a court report for litigation purposes, we will keep your information until the end of your case, unless instructed otherwise by your solicitor. We do rely on solicitors informing us when your case has ended, but we will contact them every 12 months in order to ascertain whether your case is ongoing and whether we are at liberty to destroy your records.

Job applicants, current and former CWC employees and associates

Personal information about unsuccessful job candidates will be held for 12 months after the recruitment exercise has been completed, it will then be destroyed or deleted. Once a person has taken up employment with Claire Wilson Consulting, we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment with Claire Wilson Consulting has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it.

  1. Who do we share your personal information with?

Your information is kept confidential within the Company at all times and is only shared with staff when they need it to carry out their job. All staff are required to work to strict professional and contractual codes of confidentiality and where possible we will anonymise information so that individual patients cannot be identified. All staff have signed data protection/confidentiality agreements with Claire Wilson Consulting.

If we become aware of your intent to cause harm to another person/organisation (e.g. terrorism), the law may require that we inform an authority without seeking your permission. In such a situation, the law may require that I share your personal information without your knowledge.

By contacting the Information Security Officer, by email and/or using the address below you can also get more details on:

  • agreements we have with other organisations for sharing information;
  • circumstances where we can pass on personal data without consent for example, to prevent and detect crime and to produce anonymised statistics;
  • our instructions to staff on how to collect, use and delete personal data; and
  • how we check that the information we hold is accurate and up to date,

Patients/Clients (Therapy or private assessment)

In many circumstances we will not disclose personal data without consent.

Your information may be shared with outside organisations if they are directly involved in your care/case, for instance, your insurer if they are funding your treatment, your GP, or others involved in your care. We will discuss with you who we would discuss your care with, and what details we would share with them.

If your health is in jeopardy (with your agreement) we may share your contact information with an emergency healthcare service (e.g. Mental Health Crisis Team).

However, when we investigate a complaint we may need to share personal information with other relevant bodies.

If we do need to share your information, we will always try and ask for your permission for this. We may not be able to ask your permission under special circumstances where we are legally required to do so.

Clients undertaking Court Reports

Your information is likely to be shared with organisations directly involved in your care/case, for instance, your solicitor, the defendant’s solicitor, and the court. You should contact your solicitor to find out who they might share information collected at your psychology assessment with.

  1. How you can access your information and correct it, if necessary?

Claire Wilson Consulting 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 then supply to you:

  • A description of all data we hold about you
  • Inform you how it was obtained (if not supplied by you)
  • Inform you why, what purposes, we are holding it
  • What categories of personal data is concerned
  • Inform you who it could be disclosed to
  • Inform you of the retention periods of the data
  • Inform you around any automated decision making including profiling
  • Let you have a copy of the information in an intelligible electronic form unless otherwise requested.

To make a request to Claire Wilson Consulting for any personal information we may hold you need to put the request in writing. We want to make sure that your 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 Information Security office, via “How to contact us”. We have a duty under GDPR if the request is not excessive, to provide this information within one calendar month.

Clients undertaking Court Reports

If your concern is related to a case with a solicitor that we are working for, please refer the queries through them. We may not be able to comply with a request to correct information we hold about you where it pertains to a litigation claim – this would need to be discussed with your solicitor.

  1. Your rights

You have rights around your personal data and how we handle it. If at any point you believe the information we process on you is incorrect and you want it corrected, you can request to see this information. You can also request the data to be transferred, you can object to our processing your Personal Information, or you can request to have it deleted. This has to be weighed up with our legal obligations under the health related aspects and legal aspects of our work. In such circumstances please contact the Data Protection Officer.

  1. Complaints or queries

Claire Wilson Consulting Limited tries 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 Controller who will respond. If we are made aware of any breaches or become aware ourselves, we would inform you and the ICO.

If you are not satisfied with the response from CWC 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

  1. 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.

  1. 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 23 May 2018.

  1. Who we are and how to contact us

Claire Wilson Consulting is the company that you are supplying your personal information to. The Data Controller for Claire Wilson Consulting is Dr Claire Wilson and can be contacted by:

Email: clairewilsonconsulting@gmail.com

Post:
Dr Claire Wilson
K2 Tower,
Office 1018
60 Bond Street
Hull