Privacy Policy
Data Protection & Privacy Policy
This notice is in regard to data protection laws, currently known as GDPR ( and is regarding information that is both requested by J.G. Clinical Psychology Services and that which emerges as a result of the psychology service that we provide to yourself and the child / young person you have parental responsibility for.
WHO WE ARE
J G Clinical Psychology provide therapy services to children, young people and families. Training services are also provided.
All services are provided by Dr Jennifer Gough, Clinical Psychologist.
All data processing is undertaken by Dr Jennifer Gough.
WHAT INFORMATION WE COLLECT FROM YOU / ABOUT YOU
Information collected is as follows:
Contact details (parents / carers / guardians)
Contact details (child or young person where relevant e.g. if their contact details are different to parents/ they’re over 14 and arrange sessions independently)
Relevant life data for both child and parent which may help to inform the psychological treatment plan e.g. medical history, family set up, school history, bereavements or losses, personal and emotional challenges etc.
Psychologist’s notes throughout treatment and in relation to research / further referencing undertaken to aid and enhance the work
When & where relevant, information may be requested from other professionals who have experience of your child / young person and the challenges they are facing e.g. teachers, SENCos, educational psychologists, speech therapists, GPs etc.
REASONS WHY WE COLLECT THIS INFORMATION FROM YOU
I collect this information for two main purposes:
To communicate with you by telephone and email about appointments throughout the duration of our work together
To inform the work we do together in providing psychological assessment and therapy
WHO WE MIGHT SHARE THIS INFORMATION WITH & WHY
Due to the confidential nature of the psychology services provided sharing any information given is kept to an absolute minimum. Circumstances where sharing might / will be necessary are as follows:
Clinical Supervision
Themes emerging in work with children and families are discussed with a Clinical Supervisor during supervision to ensure continuing professional development and ensure the highest quality of psychological services are provided. Identifiable information e.g. name, location will be kept to an absolute minimum. Clinical Supervisors are also registered with the ICO and comply with current UK GDPR guidance.
Safeguarding & Child Protection
If Dr Gough was made aware of any concerns about a child’s well-being including, physical abuse, emotional abuse, sexual abuse, exploitation or neglect the following process would be followed;
If deemed safe to do so the child’s caregiver/ parent would be informed of the concerns directly by Dr Gough and a referral made for additional support from the appropriate local safeguarding service. In Birmingham this would be the Children’s Advice & Support Service (CASS) which is part of Birmingham Children’s Trust.
In cases where Dr Gough has genuine concern that informing a parent/ caregiver may place a child a significant risk of harm a referral may be made without informing a parent/ caregiver in order to protect the safety of the child.
In some cases, if the concerns regard a child’s immediate safety the Police would be called.
Accountancy
Some information related to invoices for services provided will need to be shared with Dr Gough’s accountant to complete tax returns. A numerical client ID system is used to reduce the sharing of identifiable information shared with the accountant. The accountancy services employed by Dr Gough are registered with the ICO and operate within the UK GDPR requirements.
IS THE INFORMATION USED FOR ANY OTHER REASONS THAN DETAILED ABOVE?
Your information will never be used for anything other than a vital supplementary aid to the psychological assessment and therapy work we undertake together and as a means of contacting you when necessary.
HOW & WHERE IS THIS INFORMATION STORED?
Paper records
Paper records are kept to an absolute minimum to protect your information. Where paper records are required e.g. psychometric tests they are stored in a locked filing cabinet with your anonymised code. These are then scanned to an electronic format which can be stored securely (see below for electronic storage guidelines) and the paper copy is destroyed by shredding.
Electronic records
Dr Gough takes the privacy of your information seriously. The following procedures are followed to ensure protection of your personal information:
Notes are made to aid reflection on sessions. Notes are not stored with identifiable information e.g. names, DoB. Each client has a unique number code that is only known by Dr Gough.
Email communication is protected by a UK GDRP compliant encryption service called Frama Mail. This ensures that all information shared by email by Dr Gough is sent with end-to-end encryption. Further information about Frama Mail and how it meets privacy regulations for the UK can be found at Frama.co.uk
Any personal or identifiable information is stored on a hardware-encrypted storage device. This is an isolated physical storage method so your data is only accessed as and when needed and means it is protected from exposure to the internet and thus any hacking/cybercrime risk associated with storing information on computer hard-disks or in the cloud. The device is encrypted and requires a digital code to access. This device is further stored in a locked storage device.
HOW CAN I ACCESS THIS INFORMATION YOU HOLD ABOUT ME?
Any requests to access information held about you should be directed to Dr Jennifer Gough. All requests that follow UK guidance will be complied with as quickly as possible and within the timescale outlined by the ICO (currently 1 month).
Records would be shared by encrypted email and/ or in person based upon request.
For further information on your individual rights please go to https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
HOW LONG DO WE KEEP HOLD OF THIS INFORMATION?
All information will be stored for the duration of the assessment and or therapy being provided by Dr Jennifer Gough. Dr Gough will not keep information for any longer than necessary.
If you are over the age of 18 years old when we end our work together, we will continue to store your data using the methods outlined in this policy for 7 years from the date of our last contact with you in line with BPS Practice Guidelines (August 2017).
For clients who are 17 years old at the last contact with Dr Gough, data is retained until your 26th birthday. For clients under the age of 17 years old at the last contact with Dr Gough, your data is retained until your 25th birthday in line with the BPS Practice Guidelines (August 2017) and the The Records Management Code of Practice for Health and Social Care 2020.
We have the right to retain your data for these periods so that we can respond effectively to any questions or complaints that may later be raised by you and/or your representatives. After these retention periods we will erase (delete) the information I held about you securely.
HOW & WHEN WILL WE DISPOSE OF THE INFORMATION?
Paper records are kept to a minimum. Where they are used they will be scanned into an electronic format where possible and the paper copy destroyed by shredding.
Electronic records will be permanently deleted in line with the guidelines outlined above.
WHAT HAPPENS IN THE EVENT OF A DATA BREACH?
In the unlikely event of a data breach, Dr Gough will inform inform you and the ICO within 72 hours of it occurring.
Information Commissioners Office
Dr Gough is registered with the Information Commissioner’s Office www.ico.org.uk/register as the data controller for JG CLINICAL PSYCHOLOGY SERVICES (ref: ZA937908). If you have any concerns about how we are handling your data, then please contact the ICO quoting this reference for further advice on how to query or complain.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at drgough@jgclinicalpsychology.co.uk.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
