Privacy Policy

Who we are and what we do
We are the Integrated Psychology Clinic (IPC), a small group of professional, experienced and compassionate Clinical Psychologists working from our base in Marylebone, central London. We see people from across the age span for psychological assessments and interventions, and we specialise in both physical and emotional health. The practice opened its doors in 2006, and whilst we have grown and changed over the years we remain committed to providing the very best bespoke care to each and every one of our clients.

Our commitment
This policy provides an overview of how we comply with data protection legislation and the basis on which any personal data we collect from you, or that you provide to us, will be processed. Although we may need to collect and hold certain personal data in order to deliver our services to you we are committed to protecting and respecting your privacy.

Purpose of this privacy policy
This privacy policy aims to give you information on how IPC collects and processes your personal data through your use of this website and any of our services. It is important that you read this privacy policy together with any other privacy notices that we may provide on specific occasions when we are collecting or processing personal data about you or your child, so that you are fully aware of how and why we are using your data.

Controller / Contact details
The Integrated Psychology Clinic is the trading name for Netali Hutchinson LLP, and is the controller and responsible for your personal data (collectively referred to as “IPC”, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO in the following way:

Integrated Psychology Clinic
Practice Manager – admin@integrated-psychology-clinic.com
Address: ‘The House,’ 85 Wimpole Street, London, W1G 9RJ

Third Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

How we obtain personal information
We use different methods to collect data from and about you including through direct interactions, automated technologies or via third parties.

If you contact us, whether by telephone, email, website, or other means, we may keep a record of that correspondence. We may ask you to complete various questionnaires and other forms that we will use to tailor our services to your needs. We may keep records of any meetings and sessions in the form of written notes, electronic notes and audio recordings. We may receive correspondence from you or from other individuals or organisations relating to the services we deliver to you. We may also produce notes, assessments or reports. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns from analytics providers.. We collect this personal data using cookies. Please see the section further below about our use of Cookies.

What personal information we collect and how we use it
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).

The personal data we may hold on you is grouped into categories based on the way we use the information and how long we may need to retain it. These categories are explained below, along with details of what personal data we hold in each category and a brief statement of what we use it for.

Contact information
We hold contact information that you have provided to us and which we use to contact you about the delivery of services. This information may include:

your full name
your postal address
your email address
your telephone number(s), and
your online service IDs (for example Skype)

General Administration
We hold general information that you have provided to us and which we use to manage the delivery of services to you. Some of this information also enables us to comply with our legal or regulatory obligations. This information may include:

the dates, times and locations of sessions
emails relating to organizing appointments

Familial relationships
We may ask for a nominated In Case of Emergency contact to ensure that we are able to comply with sensible health and safety arrangements. If we require consent from a parent or guardian to deliver services to you, or if a family member, guardian, or other agreed person is directly involved in your case, then we may need to hold contact details for those individuals.

Sensitive information
Due to the nature of our services we may need to process data relating to your (or your child’s) physical and mental health. The General Data Protection Regulations deem data concerning health as a special category of personal data which means that we need specific reasons for processing this data. We may also need to hold some of this information in case there is a legal query. The information we hold may include:

Your name, or if applicable, your child’s name, DOB and gender.
Communication data in text messages, emails and voicemails.
Details of the mental and physical health of people within the family, including information about any health or social care you may have received from other providers such as GPs, counsellors or hospitals, as well as medications administered.
Background information relevant to the presenting problem such as family relationships.
Session notes, including a contact log, letters, notes, assessments and questionnaires associated with any support we offer, kept in accordance with guidelines from our professional body.
Details of other clinicians involved in your case, and detailed treatment notes.

We have a legitimate interest in using this data as Clinical Psychologists to provide psychological assessment and intervention, in accordance with the guidelines of our governing body. We will only use your data for the purpose of providing these services to you and for processing payment for these services.

We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver our services to you or your child). If you don’t provide us with the requested data, we will have to terminate our service for you/your child as we are unable to practice without this information.

Financial records
We are required by law to hold information on payments received for our financial records. This information may include:

your full name
your postal address
your email address
your telephone number(s)
the dates and times of sessions
the dates and amounts of payments

If you pay by cheque we may store a copy for the purpose of completing our annual accounts.

Notification data
We need to hold some information so that we can inform you in the event of a breach of your personal data. Unless you specifically ask us not to, we will hold this information for as long as we hold any other personal data about you. This information may include:

your full name
your postal address
your email address
If this information changes, please let us know as otherwise we would not be able to contact you if we needed to do so.
How we use your personal data
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:
Where expressed and informed consent has been given by the person whose data is being processed; and/or
Where it is necessary for us to perform the contract we are about to enter into or have entered into with you; and/or
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; and/or
Where we need to comply with a legal obligation.
Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new client/patient	(a) Contact (b) General Administration	Performance of a contract with you
To provide our services to you: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Contact (b) General Administration (c) Financial Records (d) Special Category Data	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Contact (b) General Administration	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Contact (b) General Administration (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Contact (b) General Administration (c) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you	(a) Contact (b) General Administration (c) Technical	Necessary for our legitimate interests (to develop our services and grow our business)

Who we share your data with
We may share your Personal Data with some other members of our team (third parties) who help us to deliver our services.

We may share your Special Category Data with other professionals or services involved in your case, for example including associate members of our practice or your GP, but we will make sure you are aware of this.

Each of our practitioners undergoes regular formal supervision. As part of these sessions it may be necessary to discuss your personal data, including special categories of personal data (‘sensitive information’), with the supervisor who will be a qualified professional operating under terms of confidentiality. We will not share with a supervisor any personal data that could be used to directly identify you.

We may also share your personal data with the external third parties set out below for the purposes set out in the table above.

Service providers acting as processors who provide payment processing, IT and system administration services.

Professional advisers acting as processors including lawyers, bankers, accountants, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal and special category 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.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

International transfers

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention and destruction
We do not keep information about you any longer than is necessary. The length of time we keep your data may be determined by statutory or regulatory requirements. We delete or destroy all personal data when it is no longer required.

A copy of our data retention policy is available to clients on request. This shows how long we would expect to keep your data and why.

Your rights under data protection legislation
You have various rights under the relevant data protection legislation. If you wish to exercise any of these rights, then please contact us in writing (see ‘How to contact us’ below).

We are confident that we will be able to answer any questions you may have, but should you feel it is necessary you do have the right to contact the UK Information Commissioner’s Office to discuss the matter further.

Subject Access
You have the right to see what personal data we hold about you. You also have the right to know where we got the data from, how and why we are processing your data, who it has been shared with, and how long we intend to keep it for.

Rectification
You have the right to ask us to investigate, and correct where appropriate, any personal data we hold about you that you believe is wrong.

Erasure
You have the right to ask us to erase personal data that we hold about you where we no longer have a lawful purpose to process the data, or where the data is being processed based on your consent which has now been withdrawn.

This right may be restricted by our need to comply with laws, regulations or other legitimate reasons that require us to retain data. However, we will tell you if this is the case.

Restriction of Processing
You have the right to ask us to restrict the processing of your personal data. Restricted processing means that we cannot make any changes to the data unless we have your consent. You can ask for restricted processing where:

You believe the data we hold is inaccurate and we need time to properly investigate,
We have unintentionally come into possession of your personal data that we should not hold but you do not want us to delete it,
Where we no longer need your personal data, but you want us to hold on to it for legal reasons, or
Where you have objected to how we use your personal data, and this is being investigated.

Once your treatment ends we will automatically restrict the processing of any personal data that we need to keep.

Right to Object
Where you feel that we are processing your personal data in a way that is inappropriate you have the right to object and so ask us to demonstrate legitimate grounds for doing so. This includes asking us not to communicate with you other than in ways you choose.

Right to not be subject to Automated Decision-making or Profiling
We do not make decisions based on automated processing or profiling.

How to contact us
If you would like any further information, or you would like to exercise any of your data protection rights, please contact admin@integrated-psychology-clinic.com