Privacy Policy

The information on this page sets out how Dr Jeffrey McDonnell, of McDonnell Psychology, complies with General Data Protection Regulation (GDPR) laws. This page was last updated on the 9th August 2023.

Data Control:

Dr Jeffrey McDonnell is the data controller for McDonnell Psychology (referred to as “we”, “us” or “our” in this privacy policy). If you have any questions about this privacy policy or our privacy practices, please contact Dr Jeffrey McDonnell via email admin@drjeffreymcdonnell.com 

The lawful basis, and reasons, for processing personal data:

Personal data is necessary for the provision of safe and effective psychological therapy to clients. If you do not provide the personal information requested, it may not be possible to provide a therapy service to you.

Dr Jeffrey McDonnell has a legitimate interest in using any collected personal data, and sensitive personal data, to provide health treatment. Privacy is taken very seriously. Personal information is only used to provide the services you have requested.

We may ask for information on how you found McDonnell Psychology for the purpose of marketing research.  No information you provide is passed on without your consent.  Your information will never be sold to others.

Personal data that is collected:

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). We collect and process the following kinds of data from clients in order to provide therapy services safely and effectively:

  • Identity data includes title, first and last name, date of birth and gender. This data is collected via a registration form which all clients are asked to complete prior to booking an appointment.  

  • Contact data includes address, email address, contact phone number, GP contact details, next of kin details and insurance information, where relevant. This data is collected via a registration form which all clients are asked to complete prior to booking an appointment.  

  • Financial data includes bank account details (only where provided by a client in order to process a refund).

  • Sensitive personal data includes information about your health, including information about your existing and previous medical conditions, medication details, psychiatric history and any other relevant health information to enable us to deliver therapy to you, as may be recorded in therapy records (therapist notes, letters, reports and/or outcome measures). Details of contacts with clients, and any financial transactions, will also be recorded. Explicit consent for processing sensitive data is required, so when you submit your details, we will send you a communication asking for you to confirm your consent to this processing. 

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. If you complete a web-based enquiry form, we will also collect any information you provide.  This is automatically supplied by the website software used to offer the form (www.squarespace.com). All web services used by McDonnell Psychology are verified by themselves as GDPR compliant.

  • Usage Data includes information about how you use our website, products and services.

  • Health Insurance Data If you are referred by your health insurance provider, we will collect, process and retain personal information provided by that organisation. This includes basic contact information, referral information, health insurance policy number and authorisations for psychological treatment.

How is personal data collected?

Different methods are used to collect personal data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms before or during an appointment, verbally during discussions at our practice, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

      • apply for our services;

      • give us feedback or contact us. 

  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using ‘cookies’ and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details: https://www.drjeffreymcdonnell.com/cookie-policy 

  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: 

    • Technical Data from the following parties:

        1. analytics providers such as Google based outside the EU; 

        2. search information providers such as Google based outside the EU.

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe or PayPal (where used) based outside the EU.

  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

How long personal data is stored for:

We will only store your personal information for as long as it is required.   For clients who engage in a course of therapy, sensitive personal data (as defined above) is stored for a period of 7 years after the end of therapy. After this time, this data is deleted at the end of each calendar year. For people enquiring about therapy (who do not become clients) the data retention period is 1 year. For clients who engage in a course of therapy, basic contact information held on a therapist’s mobile phone is deleted within 6 months of the end of therapy.

How your personal information is used:

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • To deliver therapy and process payments for therapy.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal obligation.

Who we might share personal information with:

Information is held about each client, and the therapy delivered and received, in strictest confidence. This means that personal data will not normally be shared with anyone else with the exception of a clinical supervisor and third party processors (see below). There are further exceptions to this, when there may be an established need for liaison with other parties:

  • If you are referred by your 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.

  • In cases where treatment has been instructed by a solicitor, relevant clinical information from therapy records will be shared with legal services as required and with your written consent.

  • Professionals providing accounting services (who will process contact information i.e. first and second names, as they appear on bank statements).

  • HMRC and VAT Commissioner as they require

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.

Clinical supervision:

To uphold standards of professional practice, required by regulatory bodies including the Health and Care Professions Council (HCPC), all registered practitioner psychologists are required to receive regular supervision from a qualified psychologist. During supervision, details only relevant to your treatment will be discussed. Clients will not be identified by name. Supervisory contacts are bound by confidentiality agreements (as above). 

Third Party Processors:

We use a number of third parties, who provide IT and system administration services, to process personal data on our behalf. These third parties have been carefully chosen and use Standard Contractual Clauses to comply with EU data protection regulations. These processors include:

All third party processors are required to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

What is NOT done with your personal data:

Your personal information will not be shared with third parties for marketing purposes.

Where personal data is stored:

Personal data is stored on encrypted, GDPR-compliant data servers provided by third party suppliers, including 'Cliniko’ , ‘Xero’ and ‘Tresorit’ (please see above ‘third party processors’). 

Personal data is additionally stored and accessed via a password-protected, encrypted laptop, tablet computer and mobile phone. Malware and antivirus protection is installed on all computing devices. Mobile and computing devices are protected with a passcode/thumbprint scanner, mobile security and antivirus software. 

How the security of personal information is ensured:

Personal information is minimised in phone and email communications. 

Any sensitive personal data which needs to be sent to clients will be transmitted via an encrypted link or password-protected email attachment (using ‘Tresorit’ encryption services). Email applications use private (SSL) settings, which encrypts email traffic so that it cannot be read at any point between our computing devices and our mail server. McDonnell Psychology will never use open or unsecured Wi-Fi networks to send any personal data.

How security is ensured for online appointments:

  • For online meetings Zoom, an end-to-end encrypted video calling service, is used. 

  • Zoom is free to download from the internet; more can be read about how Zoom protects its users here: zoom.us/docs/en- us/privacy-and-security.html. 

Your legal rights:

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  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 we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we 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. McDonnell Psychology reserves the right to refuse a request to delete a client’s personal information where this is therapy records. Therapy records are retained for a period of 7 years in accordance with the guidelines and requirements for record keeping by The British Psychological Society (BPS; 2000) [1] and The Health and Care Professions Council (HCPC; 2017) [2].

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 

  • If you want us to establish the data's accuracy.

  • Where our use of the data is unlawful but you do not want us to erase it.

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. 

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us via admin@drjeffreymcdonnell.com. 

  • 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 could refuse to comply with your request in these circumstances.

  • What we may need from you

We 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. We may also contact you to ask you for further information in relation to your request to speed up our response.

  • Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to the privacy policy

We keep our privacy policy under regular review. This version was last updated in August 2023. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes if we are working together on an ongoing basis.

Other (linked) websites

This website may include links to third-party websites, plug-ins and applications. Our privacy policy only applies to this website; we would encourage you to read the privacy statements on any other websites you visit.

Complaints or queries

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (visit ico.org.uk/concerns or phone 0303 123 1113). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance if possible. We would also welcome any suggestions for improving our procedures.

____________________ 

Dr Jeffrey McDonnell 

Chartered Clinical Psychologist & Owner of McDonnell Psychology.

Updated August 2023

 

[1]       The British Psychological Society (2000). Clinical Psychology and Case Notes: Guidance on Good Practice. Leicester: Division of Clinical Psychology, BPS.

[2]       Health and Care Professions Council (2017). Confidentiality – guidance for registrants. London: HCPC.