Every psychologist is bound by law to maintain client files that hold information such as name, address, date of birth, BSN, GP’s name, prescribed medication, reference letters as well as the outcome of assessments and session logs. Our clients’ privacy is very important to us and we maintain a combination of carefully supervised protocols and IT measures to protect it. Psychologist at PEP International fully comply to the European Union’s General Data Protection Regulation as well as to the Dutch Wet op Geneeskundige Behandelovereenkomst (Medical Treatment Agreement Act). These precautions lead to the following:
– Your private data will only be used for the intended means stated underneath.
– We will only process the minimal amount of data necessary for the treatment.
– PEP International will ask for your consent to process this data and ask for additional consent if it is necessary to share (parts of) this data with other healthcare professionals in connection to further treatment by a third party.
All psychologists at PEP International are personally responsible for the protection of your privacy. In case you have any questions or complaints regarding the processing of your private data please do not hesitate to write an email to firstname.lastname@example.org
For what means does PEP International process private data?
– General and financial administration
– Registration of admissions
– Psychotherapeutic treatments and assessments
– Routine outcome monitoring (ROM, measuring the effect of treatment)
– Communication with other healthcare professionals if needed
– Declaration of treatment costs for the insurance
Routine Outcome Monitoring (ROM)
PEP International makes use of a ROM system in order to measure efficacy. The measurements will take place at the start, during and at the end of the treatment and also being used as a basis for discussing the course of a treatment with a client. Your data (Name, email address and outcome) will be stored on IT systems by BergOp and Questmanager, who also fully comply with the European Union’s General Data Protection Regulation. Through an agreement with the Stichting Vrijgevestigden ROMmen (SVR) we furthermore provide anonymized data about treatment effects with the Stichting Benchmark GGZ (SBG), a Dutch government agency in charge of supervising treatment efficacy.
Providing private data to third parties
Psychologists working at PEP International are bound by law to keep your private data secured from third parties. This also includes that in case we are contacted by someone who is not an integral part of the treatment process, we will neither deny nor confirm that a client is seeing us. There are, however, exceptions to this. Firstly, we will inform your GP about the process of the treatment. The content of our communication with your GP will only be as detailed as necessary. Secondly, it can be possible that another healthcare professional needs to be involved, e.g. in case the integration of pharmacotherapy needs to be discussed. Before this third party will be able to access your data, we will ask for a specific consent. Thirdly, in case we are convinced that you might form a danger for yourself or for others, we are bound by law to disclose information and inform the authorities. Yet, this is extremely rare and this step will only be taken after thorough consideration.
According to Dutch and European Laws, we are only allowed to process private data from clients younger than 16 years if we received the consent by a parent or caretaker. Parents and caretakers of clients younger than 12 years always have the right to access their child’s data. For clients between 12-16 parents/caretakers and clients may access their data. For clients older than 16 years of age we will process private data after consent by the client him-/herself and access to the data by parents or caretakers will only be allowed after consent by the client.
Duration of storage
PEP International will data not longer than necessary and demanded by law.
Your rights in connection to your stored data
Initially nobody else besides you and your psychologists will have access to your personal data. In case you gave consent for access through a third party you can also revoke this consent at any time. You also have the right to access data stored about you at any time, yet, with some limitation. Files containing your private data are the property of PEP International but we will provide you with a printout or PDF of your whole or parts of your file on demand. This process might lead to extra costs for a client.
Change and removal of data
In case some of your stored data is outdated, wrong or incomplete, you can ask your psychologist to edit it. Privacy laws demand this process to happen in written form and needs to be fulfilled within two months. If your psychologist is not willing to change or edit any data, he/she is bound to state why. You have furthermore the right for the removal of (parts of) your data, in which case information in your file will be replaced by the removal request.
Diagnostic information for your health insurance
Psychologists need to provide the diagnostic section and very short description leading to the necessity for treatment to your health insurance in order to be able to bill it. However, clients have the option to opt-out of this by signing the necessary privacy form that will be provided to you by your psychologist.