Silvadawn Ltd Company no. 3621054
You may be aware of new laws relating to General Data Protection Regulation (GDPR) that are in effect from 25 May 2018. The purpose of GDPR is to provide a set of standardised data protection laws across all EU member countries. This document sets out how Dr Abigail Pamich, Director complies with these laws.
Dr Abigail Pamich is the data controller for Silvadawn Ltd. Associate therapists taking on referrals with Silvadawn Ltd will be additional data controllers for the clients they work with directly and may have access to more data than Dr Pamich due to the confidential nature of their therapy work with a specific client. In such cases, associates will be the primary data controller for those clients.
What personal data we process
Silvadawn Ltd collects and processes the following personal data from therapy clients:
- Personal data: basic contact information: name, address, email, contact number, video conference ID (if online therapy), and GP contact details.
- Sensitive personal data: Signed Consent to the Therapy Agreement, therapy records (therapist notes, letters, reports and/or outcome measures).
If you are referred by your health insurance provider, we will also collect, and process personal data provided by that organisation. This includes basic contact information, referral information, and health insurance policy number and authorisation for psychological treatment.
The lawful basis for processing personal data
Silvadawn Ltd has a legitimate interest in using the personal data and sensitive personal data we collect to provide mental health treatment. It is necessary for us to collect this date to be able to provide psychological therapy to clients and to identify clients should an issue or risk arise and the GP needs contacting. We may also ask for information on how you found our service for the purpose of our own marketing research. No information you provide is passed on without your consent. We will never sell your information to others.
What we do with your personal information
We take your privacy seriously. We will only use your personal information to provide the services you have requested from us. If you do not provide the personal information requested, then we may be unable to provide a therapy service to you as we have to collect identifiable information in case there is a concern regarding risk to self and others and we need to contact a third party concerning this risk.
How long we store personal information
We will only store your personal information for as long as it is required by standard for our service and governing bodies. The sensitive personal data defined above is stored for a period of 7 years after the end of therapy. After this time, this data is deleted at the end of each calendar year. No card payment details are stored, they are all taken using licensed payment process Software of Izettle or Stripe.
How your personal information is used
We use the information we collect to (1) Provide our services to you (2) Process payment for such services via card using licenced software called Izettle and Stripe. (3) send you information related to a change in our services.
Sharing your information
We hold information about each of our clients and the therapy they receive in confidence. This means that we will not normally share your personal information with anyone else. However, there are exceptions to this when there may be need for liaison with other parties:
- If you are referred by your health insurance provider, or otherwise claiming through a health insurance policy to fund therapy, then we will share appointment schedules with that organisation for the purposes of billing.
We may also share information with that organisation to provide treatment diagnosis and updates if this is requested.
- In cases where treatment has been instructed by a solicitor, relevant clinical information from therapy records will be shared with legal services as required and with your written consent.
In exceptional circumstances, we might need to share personal information with relevant authorities:
- When there is need-to-know information for another health provider, such as your GP.
- When disclosure is in the public interest, to prevent a miscarriage of justice or where there is a legal duty, for example a Court Order.
- When the information concerns risk of harm to the client, or risk of harm to another adult or a child. We will try to discuss such a proposed disclosure with you unless we believe that to do so could increase the level of risk to you or to someone else.
What we will NOT do with your personal information – We will not share your personal information with third parties for marketing purposes.
How we ensure the security of personal information
Personal information is minimised in phone and email communication. We use a password protected Wifi and information stored on the computer and work phone is password protected. Any information stored on third party servers e.g. OneDrive is protected with two factor authentications.
Personal information is also stored on an office computer and on a secure server owned by Silvadawn Ltd. These are password protected. Malware and antivirus protection are installed on all computing devices. Mobile devices are protected with a passcode and all Associate Therapists are under contract to follow the same security procedures.
Your right to access the personal information we hold about you
- You have a right to access the information we hold about you.
- We will usually share this with you within 30 days of receiving a request.
- There may be an admin fee for supplying the information to you.
- We may request further evidence from you to check your identity.
- A copy of your personal information will usually be sent to you in a permanent form (that is, a printed copy).
- You have a right to get your personal information corrected if it is inaccurate.
- You can complain to a regulator. If you think that we haven’t complied with data protection laws, you have a right to lodge a complaint with the Information Commissioner’s Office.
Silvadawn ltd reserves the right to refuse a request to delete a client’s personal information where this is therapy records. Therapy records are retained for a period of 7 years in accordance with the guidelines and requirements for record keeping by The British Psychological Society (BPS; 2000)  and The Health and Care Professions Council (HCPC; 2017).
Dr Abigail Pamich Clinical Psychologist & Owner
The British Psychological Society (2000). Clinical Psychology and Case Notes: Guidance on Good Practice. Leicester: Division of Clinical Psychology, BPS.
Health and Care Professions Council (2017). Confidentiality – guidance for registrants. London: HCPC.