Privacy Notice
Privacy Notice according to the General Data Protection Regulation
Ms. Nataly Loumba
Licensed Counseling Psychologist
Introduction
The privacy notice is created by Ms. Nataly Loumba (i.e., the psychologist) with the aim of complying with the General Data Protection Regulation (GDPR). Your personal information can help us understand your needs and offer you services of higher quality. However, we understand that safeguarding your data privacy is a big responsibility which we take very seriously. Therefore, the present privacy notice was put together in order to offer information on the ways that your data will be collected and processed, the prevention of possible data breach as well as your rights as a consumer.
Definitions
“personal data”: every piece of information in regards to an identifiable person.
"data processing": every collection, saving, organizing, use, limitation or deletion of personal information that have come or will come to the psychologist’s attention.
“personal data breach”: the violation of the security that leads to an accidental or illegal destruction, loss, unauthorized publication or access to data that have been transferred, saved or processed in any other way.
Personal Data Processing
The psychologist processes personal data:
In order to communicate with you, either face-to-face, or online via Skype or Zoom, so that she can respond to inquiries and/or arrange appointments. If you send an inquiry, the psychologist can contact you in order to obtain further information necessary to the answering of your inquiry and/or to determine whether her services are appropriate according to the presenting issue. For this purpose, the psychologist must process any data that are submitted via online platforms, e-mail or social media platforms.
In order to offer the psychological services either face-to-face at the psychologist’s office or online via Zoom or Skype.
In order to understand your personal situation and form a clinical opinion so that the appropriate services can be offered.
In order to inform you on upcoming seminars, workshops or other mental health services, after you have given your written permission. You may withdraw this permission at any time.
In order for the psychologist to comply with the current laws, European regulations, legal decisions and other legal procedures.
In order to defend the psychologist’s legal rights.
2. Collection of personal data
The collection of your personal data is limited to the data necessary for the achievement of the goal for which they have been collected. The collection may be achieved via the following ways:
Information that you share voluntarily when first communicating with the psychologist (face-to-face, via phone/e-mail/social media platforms)
Information that you share voluntarily when completing the contact form on the psychologist’s website
Information collected via mental health questionnaires
Information you share within the therapeutic sessions
Information you share voluntarily outside of the therapeutic sessions (via phone/e-mail/social media platforms)
Information shared by other health professionals (e.g., general practitioner) after giving your permission
In case the psychologist intents to process personal data further, for a purpose other than the one for which the data had been collected, the psychologist must provide you, before proceeding with the processing, information in regards to the purpose of this activity and, whenever necessary, your permission will be obtained prior to the processing.
Type of data that is collected
The psychologist, as a mental health professional, may collect the following personal and sensitive data during the first session and the course of therapy, which are used towards the successful completion of the therapeutic procedure for the clients who receive services:
Name, surname
Address
Age/Date of birth
Gender
Phone number and other contact details
Bank information (e.g., IBAN)
Relationships and family information
Profession
Psychological intervention history or history of other psychiatric diagnoses
Current and previous psychological difficulties
Information on psychological issues and concerns
Social network, professional life, lifestyle, daily activities etc.
Contact details of an emergency contact that the psychologist could contact (in case of an emergency)
Interventions taking place during the treatment
Issues that come up during the sessions
Sensitive data
Personal data that reveal ethnical background, political views, religious beliefs or other philosophical beliefs
Participation in a syndicate
Health information
Data in regards to sexuality, sexual life or sexual orientation
Data in regards to legal violations or criminal acts
Also, prior to the first session, and according to the contact medium that you select to come in contact with the psychologist, the psychologist may collect your name and surname, your e-mail address, your phone number, and a short description of the presenting problem so that she can determine whether her services are appropriate for your individualized needs.
3. Saving and management of personal and sensitive data
Personal data are processed, maintained and stored by the Psychologist in a secure environment, solely for the purposes for which they are intended and in compliance with the applicable laws.
The data provided by you is retained only for as long as it is required to fulfill the purpose for which it was notified and only for as long as it is required to achieve those objectives, subject to cases where it is reasonably required by law or regulation. Please contact the psychologist for precise updates on the retention time.
4. Transmission of Personal Data
The personal and sensitive data collected is not transferred to third parties or organizations unless the psychologist has a legal obligation to break confidentiality with you.
In special cases, information exchange with other Health Professionals may occur if therapeutically necessary. In some cases, the general practitioner or other professionals involved in mental health care must be informed about the client’s psychological treatment, always in the context of medical confidentiality that binds all health professionals. This may include sending evaluation / progress reports or conducting phone conversations where personal and sensitive information is transferred. If this is deemed necessary you will always be informed about the type of information, the reason and the procedure for transferring the information. Prior to sending any document / report to another health care professional, you will be entitled to request modification of this document and with your consent. The GP and other healthcare professionals should comply with the GDPR (this will be checked before sending any confidential information).
5. Your rights as far as your personal data protection is concerned
You have the following rights:
The right of access to personal data and obtaining information about them, as well as their origin, their processing purposes, their recipients or types of recipients, and their storage period.
The right to correct inaccurate data and to fill in incomplete data. You can check and update your personal information by always displaying the necessary supporting documents, requesting correction or filling in inaccurate information.
The right to restrict the processing of data, provided that either their accuracy is questioned, their processing is unlawful, or the purpose of the processing is no longer fulfilled, provided that there is no legitimate reason to retain it.
The right to data portability, that is, the transfer of your personal data to another organization in a form that is identifiable and commonly used. The implementation of this right is not violating the legal rights and obligations of the Psychologist.
The right to object to the processing of data concerning yourself. You may object to the processing of your data and the processing of your data will be terminated if there are no other compelling and legitimate reasons that prevail over your right.
The right to delete part or all of the data relating to you, without it affecting, however, the obligations and legal rights of the Psychologist to retain them for a limited period of time, under the applicable legal and regulatory framework.
The right to withdraw consent at any time of your consent to the processing of your personal data without affecting the legality on which the processing was based prior to your withdrawal. Please be advised that revoking your consent may lead to termination of services.
The psychologist believes that all the information she processes is valuable and necessary for her legitimate purpose of providing services to her clients, and that their protection is the highest priority.
If you wish to exercise your right as a data subject or if you have any questions about the protection of your personal data, you can send an email to natalyloumba@gmail.com. The psychologist must provide information on the processing performed upon request without delay and in any case within one month of receipt of the request. This period may be extended by a further two months, if necessary, taking into account the complexity of the request and the number of requests.
If you feel that you have been wronged in the course of your complaint or if you have doubts about the outcome of your request, you may also submit it in writing to the Commissioner for Personal Data Protection at:
Office of the Commissioner for Personal Data Protection
Iasonos 1, 2nd floor
1082 Nicosia
P.C. 23378
1682 Nicosia
Tel.: +357 22818456 Fax no.: +357 22304565
E-mail: commissioner@dataprotection.gov.cy
6. Corrections and Changes to the Privacy Policy
Changes in Legislation or technological developments also require corresponding changes. Please be aware that our policy may change at any time and be adapted to new developments and data.
Our revised policy will be posted on our website at www.natalyloumba.com
Finally, you can request a copy of the most recent version of the Policy in hard copy.
November 2019