You can trust me.
I take your privacy very seriously
Transparancy about the use of your personal data is my highest priority
Privacy policy (AVG)
In Balans Counseling & Coaching
Everything you need to know about how I handle your personal data.
Your privacy
In Balans Counseling en Coaching, located at Klip 143, 8224CJ, Lelystad, is responsible for processing the personal data as stated in this privacy policy.
Contact Klip 143, 8224 CJ, Lelystad. Nirmala Ramessar is the Data Protection Officer at In Balans Counseling en Coaching. You can reach her on info@InBalansCC.nl
Personal data that is being processed
In Balans Counseling en Coaching processes your personal data because you use her services and/or because you provide the data yourself.
For proper therapy, it's essential that I - as your therapist - start a client file. This is also a legal obligation, imposed by the WGBO. Your file consists of notes about your health situation and data about executed tests and treatments.
Other data, provided by other healthcare parties like your GP, that is needed for proper therapy, will also be added to your file after your explicit permission.
I'll do my best to safeguard your privacy. This means among other things, that I will:
- Handle your personal and medical data with care;
- Protect your data from third parties.
As your treating therapist I'll be the only one with access to your files.
I'm legally obligated to confidentiality (professional secrecy).
Data from your client file can be used for the following purposes:
a. To inform other health authorities, for example when I refer your to another therapist. This only happens with your explicit permission.
b. To be used by an observer, during my absence.
c. For anonymized use during peer reviews.
d. A small part of the data from your file will be used for financial administration purposes. So I - or my administrator - can issue an invoice.
If I want to use your data for any other reason, I have to inform you and ask for your explicit permission.
Retention period personal data:
De gegevens in het cliëntendossier blijven zoals de wet op de behandelovereenkomst vereist 7 jaar bewaard.
Privacy on your care bill
Data which is needed by your health insurer for compensation, will be stated on your care bill.
- Your name, address and hometown;
- Your date of birth;
- The therapy date;
- A short note of the type of therapy, for example 'therapy naturopathy', or 'psychosocial consult';
- The consult costs.
Personal data that's retained in your client file
- Name, address, postal code, hometown of client(s);
- Client(s) date of birth;
- Client(s) phone number.
In the case of underage clients:
- Also the name, address, postal code, hometown, telephone number and e-mail address of both parents.
When it's essential for proper therapy, I'll need the following data:
- General practitioner;
- School of underage client.
When it's essential for proper therapy, I'll need the following special personal data:
- Religion or beliefs;
- Health situation;
- Sexuality;
- Potential legal data like information from youth services or about violence issues within the family.
Purpose of personal data that's being processed by me
Next to the AVG, the WGB and professional code
of my professional association (CAT) and the RBCZ are applicable.
These are all leading in the way I file my clients personal data.
That's why I handle personal data in the following way:
1. File obligation
Based on the Wet op Geneeskundige Behandelingsovereenkomst (WGBO) I'm obligated as a therapist to keep a medical file.
2. Retention period
De hoofdregel voor het bewaren van medische dossiers staat in de WGBO. Dat is 20 jaar, gerekend vanaf de datum van vastlegging van ieder afzonderlijk gegeven. De termijn kan langer zijn indien dit noodzakelijk is met het oog op de behandeling (bijvoorbeeld indien iemand een chronische ziekte heeft).
3. Professional secrecy
Based on my professional code the legal professional secrecy, as a therapist I'm obliged to stick to data confidentiality. Employees of apsychosocial or complementary practice are bound to professional secrecy by employment contract.
5. Underage clients
Based on patient rights from the WGBO, mentally competent underage clients aged 12-16 share authority with their parents. Parents of clients up to 16 years old have the right to co-decide about therapy. Parents have the right to access information and the client file, when this is applied to the co-decision law linked to the therapy. There is an exception to this right, when the healthcare professional thinks this will collide with the interests of the client. Mentally competent clients aged 12 years or older are authorized to give permission to break the confidentiality agreement.
How the client is informed
- I inform clients about my file obligation during the intake session.
- I ask my website visitors for their e-mail address and such and explain why I need the personal data and what I'll do with it.
Who actually handle the client files?
- As a self employed therapist I'm the only one with access to the client files. I have a secrecy obligation based on my professional code.
- Sometimes I discuss actual cases with colleagues or a peer group. But the cases are always anonymized.
Client file security
- I work with paper client files. These are stored in a locked cabinet.
- I work with a digital client file. This is secured by a password.
When should I report a data breach?
I'm obligated to report data breaches since January 1st 2016. This means that organizations (including therapists) have to report a data breach to the 'Autoriteit Persoonsgegevens' withing 72 hours after the incident.
Examples of data breaches are: a lost USB-stick with personal data, a stolen laptop or a hacked digital database.
√ I understand when to report a data breach and will handle accordingly.
Nirmala Ramessar, CAT3 Therapist
In Balans Counseling en Coaching
info@inbalanscc.nl
Date: 29-04-2020