book a consultation

Privacy Policy

Welcome to Glow Psychology’s Privacy Policy, which is run by Dr Gursharan Lotey. 

This privacy policy will describe how Glow Psychology collects, stores, processes and shares the information you have provided. Here at Glow Psychology, your privacy and confidentiality is taken very seriously. Glow Psychology wants all their clients to feel safe discussing their feelings and concerns as openly as possible and ensures the highest level of confidentiality and security. 

The information you provide for the purpose of working together will be explained as well as your rights to the information in how it is collected, processed and shared. You are required to agree to the conditions set out in the Privacy Policy in order for your enquiry to be processed and for you to receive a service. 

You are welcome to get in touch if you have any questions or concerns about this privacy policy by emailing hello@glowpsychology.co.uk.  

I am the named data protection lead at Glow Psychology, including the data controller and data processer with the Information Commissioner’s Office (ICO). I follow the codes of practice set by my professional regulatory body, the Health and Care Professions Council (HCPC). Any personal information held about you is stored and processed in line with the Data Protection Act (DPA, 1998) and the General Data Protection Regulation (GDPR, 2018). 

You have the right to request a copy of your data and information, without charge, and you have the right to have any inaccuracies corrected. More about this will be explained below. 

What data I collect and how?

I am required to collect data and information about you in order to provide a service to you and to process payments. I collect personal data which is any identifiable information such as your name, DOB and address , as well as sensitive data such as your personal and family history. Other data is also collected including bank account details, healthcare information such as your GP or other healthcare professionals. 

Glow Psychology uses a number of methods to communicate and collect information about you including: 

  • Website: we will collect your personal data when you use our website, including the use of our contact form. 
  • Text and Telephone: Using your contact number we may call you and other people connected to your care to gather information as part of the assessment, intervention, supervision, consultation or training services. 
  • Email: I may use email to communicate with you and other third parties connected to your care, for example about appointment reminders. I kindly ask that you do not share sensitive personal information, such as details about your situation or that of another person via email. If we need to communicate sensitive information via email, we will use a more secure method, such as password-protected documents and/or secure email systems.
  • In-person: I will meet with you and take written notes when talking about your care. 
  • Written communications: We may use other forms of written communication including letters to communicate with you and others connected to your care. I will also ask you to complete forms as part of the assessment, intervention, supervision, consultation and supervision. 
  • Third parties: I may collect personal data about you from other third parties such as other health and social care providers or schools. We may also use search analytics providers to provide us with personal data about people accessing our website. 
  • Website: We will collect technical data which includes your use of accessing and using Glow Psychology’s website and online services, and using online analytics providers such as Google Analytics. The information and data available will be your IP address, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website.  The source of this data is from our analytics tracking system.  We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and decide our marketing strategy.

I require your explicit consent for processing sensitive data, so when you submit your details, you will be given further consent forms and my Terms and Conditions, asking for you to confirm your consent to this processing.

Why is this data gathered:

All the data gathered is relevant to providing a service and to continue to provide you a service that is of the highest quality care. Glow Psychology has a lawful basis for collecting, storing, processing and sharing your personal data which relates to having a ‘legitimate interest’ and for the ‘provision of health treatment’. You can find out more about the lawful basis for personal data collection here: www.ico.org.uk.

Collecting this data as part of providing a service to you helps in the following ways:

  • Make sure you are getting the right service for you. 
  • To ensure the service provided is helpful for potential clients requiring a service. 
  • Have up to date and accurate information to get in contact with you to help set up the right service for you. If your personal data changes, please notify us at the earliest opportunity to ensure accuracy and that our records are always up to date. This is important for data protection and for safety purposes. 
  • Use this information to carry out psychological assessment and psychological therapy. 
  • Provide invoices to you for the services provided and received. 
  • Communicate with relevant third-parties to support your treatment and manage risks (where necessary and agreed with you). 

Sharing Data

Your data and information will not be shared without your knowledge. Where it is appropriate and clinical necessary, and with your permission, we will share information with other relevant parties including your GP, next of kin etc. Please also see the Terms and Conditions (link to Terms and Conditions) for more information about breaking confidentiality and sharing without your consent. 

Clinical psychologists are also required to have regular supervision to maintain high standards, and so data may be shared with a supervisor.  Steps will be made to protect you and your family’s identity.  We use first names only and do not share identifying details with our external supervisors. 

We will never use or share your personal information for marketing purposes. 

How long I keep the data

Data is kept for as long as the client remains open to the service and for a period of 7 years thereafter discharge from the date of the last contact with you. This includes electronic clinical notes. This is to help respond effectively to any questions or complaints made by you in future. After this period, your data will be disposed of effectively and securely. You have the right to request for your data to be destroyed after this 7 year period but not before this. If you are a child, they will be destroyed when you, or your child turns 18.

Where data is kept and stored: 

All data will be stored in a safe and secure way and will comply with GDPR standards. Data is stored in the following ways and places:

  • In clinic management software (Writeupp and/or Cliniko)
  • On my personal laptop including formulations and documents which may be related to your care and any treatment you may receive
  • In a paper file, including any forms you complete or paper documents we write on in sessions. 
  • Mobile phone device
  • Email systems

How I keep data safe 

  • Clinical software such as Writeupp and Cliniko is GDPR and ICO compliant which means that data is encrypted and securely kept. Most of your personal and sensitive data will be stored here. 
  • The laptop is encrypted using Apple’s full-disk FireVault. 
  • Any paper documents which contain personal or sensitive data is stored in a secure and locked cabinet if it cannot be transferred to your electronic notes.
  • The mobile phone is encrypted, and must be opened with a password or face ID each time I use it. 
  • My email systems are secured with a password which is routinely changed.
  • Access to the analytics on my website are secured with a strong password.

Data breach

In the unlikely and unfortunate event of a data breach, ICO will be notified immediately where appropriate procedures will be followed. You will also be informed of such events. 

Yours rights: 

You have the right to the following as a client of Glow Psychology. You are entitled to receive the relevant data within 30 days of your request to have access to them:

  • Ask what information is held about you and why
  • Access – Ask to gain access to a copy of your information 
  • Request correction and amendments
  • Request erasure of data although this may need to be checked with the HCPC if it is before the 7 year period.
  • Request restriction of processing
  • Request transfer of data to another service and we will be happy to provide a summary of the work we have done. 
  • The right to withdraw consent. 
  • Be informed how your data is kept safe and meets protection regulations. 

If you wish to make any requests, please contact the Data Protection Lead at Glow Psychology. You do not have to pay any fees to request access to your data or to receive the data itself. There may be times where an appropriate fee is charged if the request is repetitive, excessive or unfounded. If such a request is made, then we may require specific information from you to ensure your identity and right to access your personal data. 

Zoom

For online sessions, the Zoom app is used. All Zoom online sessions will have enabled end-to-end encryption which means the link is secure and safe to use. It is also a requirement that any participants to the Zoom link will require admission to the session by me, which enhances security. Zoom sessions are not recorded, unless in unique and special circumstances, but which will require your explicit consent to do so. You may wish to check their privacy policy here (https://zoom.us/privacy) before utilising their service.

Cookies

This website uses cookies so that I can track activity such as how many people have visited and which pages are most popular. Google may send additional cookies if you use the google map links on the site. Cookies are anonymous and contain no personal data. You can turn cookies off in your website browser if you wish to, but this may affect your viewing preferences.

Complaints

If you have any questions, concerns or complaints in regards to how your data could be collected, stored or processed, please get in touch with the Data Protection Lead at Glow Psychology. It is important that any enquiry is dealt with and resolved to your satisfaction as soon as possible. You also have the right to complain to the ICO and can find out more information by visiting www.ico.org.uk. 

We reserve the right to update this privacy policy. The privacy policy was last updated July 2022.