Who we are and what we do
I (Anastassis Spiliadis) established ICF Consultations (Individual Couple Family Consultations & Psychotherapy) as an independent psychology and psychotherapy practice in 2018 in London. Having worked both in the NHS and in private practice for many years, I decided to develop an independent service that would allow me to work flexibly with people experiencing a range of emotional, relational and physical difficulties. ICF has two main bases – in Central London and in Athens. I see people from across the age span for psychological assessments and psychotherapeutic interventions.
My commitment
This policy provides an overview of how I comply with data protection legislation and the basis on which any personal data I collect from you, or that you provide to me, will be processed. Although I may need to collect and hold certain personal data in order to deliver my services to you, I am committed to protecting and respecting your privacy.
How I obtain personal information
If you contact me, whether by telephone, email, website, or other means, I may keep a record of that correspondence. I may ask you to complete various questionnaires and other forms that I will use to tailor my services to your needs. I may keep records of any meetings and sessions in the form of written notes, electronic notes and audio recordings (the latter only with written consent). I may receive correspondence from you or from other individuals or organisations relating to the services I deliver to you. I may also produce notes, assessments or reports.
What personal information I collect and how I use it
The personal data I may hold on you is grouped into categories based on the way we I the information and how long I may need to retain it. These categories are explained below, along with details of what personal data I hold in each category and a brief statement of what I use it for.
Contact information
I hold contact information that you have provided to me and which I 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 or Doxy)
I do not hold or store any information relating to your social media
General Administration
I hold general information that you have provided to me and which I use to manage the delivery of my services to you. Some of this information also enables me to comply with my legal or regulatory obligations. This information may include:
the dates, times and locations of sessions
emails relating to organizing appointments
familial relationships
I may ask for a nominated In Case of Emergency contact to ensure that I am able to comply with sensible health and safety arrangements. If I 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 I may need to hold contact details for those individuals.
Sensitive information
Due to the nature of the services I offer I may need to process data relating to your physical and mental health. The General Data Protection Regulations deem data concerning health as a special category of personal data which means that I need specific reasons for processing this data. I may also need to hold some of this information in case there is a legal query. The information I hold may include:
Your health history
Details of other clinicians involved in your case, and detailed treatment notes.
Financial records
I am required by law to hold information on payments received for my 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
Notification data
I need to hold some information so that I can inform you in the event of a breach of your personal data. Unless you specifically ask me not to, I 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 me know as otherwise I would not be able to contact you if I needed to do so.
Who I share your data with
I may share your Special Category Data with other professionals or services involved in your case, for example including associate members of my practice or your GP, but I will make sure you are aware of this.
As a UKCP and BPS registered clinician I undergo formal clinical supervision. As part of these sessions it may be necessary to discuss your personal data, including special categories of personal data (‘sensitive information’), with my supervisor who will be a qualified professional operating under terms of confidentiality. I will not share with a supervisor any personal data that could be used to directly identify you.
Data retention and destruction
I do not keep information about you any longer than is necessary. The length of time I keep your data may be determined by statutory or regulatory requirements. I delete or destroy all personal data when it is no longer required.
A copy of my data retention policy is available to clients on request. This shows how long I 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 me in writing.
I am confident that I 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 I hold about you. You also have the right to know where I got the data from, how and why I am processing your data, who it has been shared with, and how long I intend to keep it for.
Rectification
You have the right to ask me to investigate, and correct where appropriate, any personal data I hold about you that you believe is wrong.
Erasure
You have the right to ask me to erase personal data that I hold about you where I 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 my need to comply with laws, regulations or other legitimate reasons that require me to retain data. However, I will tell you if this is the case.
Restriction of Processing
You have the right to ask me to restrict the processing of your personal data. Restricted processing means that I cannot make any changes to the data unless I have your consent. You can ask for restricted processing where:
You believe the data I hold is inaccurate and I need time to properly investigate,
I have unintentionally come into possession of your personal data that I should not hold but you do not want me to delete it,
Where I no longer need your personal data, but you want me to hold on to it for legal reasons, or
Where you have objected to how I use your personal data, and this is being investigated.
Once your treatment ends I will automatically restrict the processing of any personal data that I need to keep.
Right to Object
Where you feel that I am processing your personal data in a way that is inappropriate you have the right to object and to ask me to demonstrate legitimate grounds for doing so. This includes asking me not to communicate with you other than in ways you choose.
Right to not be subject to Automated Decision-making or Profiling
I do not make decisions based on automated processing or profiling.
How to contact me
If you would like any further information, or you would like to exercise any of your data protection rights, please see my contact page for details.
