Clinical Data Processing & Privacy Notice
1. Data Controller
Totality Psychology is the "Data Controller" for all personal and clinical information processed. HCPC-registered Clinical Psychologists are responsible for ensuring your data is handled securely and in accordance with UK law.
2. Types of Information Collected
In addition to basic contact details, we collect sensitive Special Category Data necessary for your care, including:
- Full clinical and psychological history.
- Detailed session notes and therapeutic formulations.
- Relevant medical information, including prescribed medications and GP details.
- Standardized psychometric test results and assessment data.
3. Lawful Basis for Processing
Under UK GDPR, we process your data using the following legal frameworks:
For Clinical Care: We rely on Article 6(1)(f) (Legitimate Interests) and Article 9(2)(h) (Processing necessary for the provision of health or social care or treatment). This ensures we can maintain the accurate clinical records required by the HCPC.
For Enquiries: We rely on Article 6(1)(a) (Consent) when you use our website contact form.
4. Data Storage and Security
We utilize specialized, encrypted platforms to ensure the highest level of security for your clinical records:
- Clinical Records: All notes and assessments are stored in the Jane app, a GDPR-compliant practice management system.
- Financial Data: Invoicing and payments are processed through Wise Business, ensuring secure financial transactions.
- Encryption: All digital data is encrypted both "at rest" and "in transit".
5. Retention Periods
In accordance with UK clinical guidelines and HCPC standards, we retain adult mental health records for a minimum of 20 years (or 8 years after the patient’s death, whichever is longer) to ensure continuity of care and meet legal requirements. For clients who were under 18 at the time of treatment, records are retained until their 25th birthday (or 26th if they were 17 when treatment ended).
6. Your Rights
Under UK GDPR, you have the right to request access to your records (Subject Access Request), the right to rectification of inaccurate data, and the right to object to certain types of processing.
7. Legal Notice & Regulatory Notice
Totality Psychology Inc. is a corporation registered in British Columbia, Canada. Psychological services are provided exclusively to residents of the United Kingdom via secure telehealth by a Practitioner Psychologist registered with the UK Health and Care Professions Council (HCPC # PYL044369).
The practitioner does not provide services to individuals physically located within Canada. All personal data is handled in compliance with UK GDPR standards. As a Canadian entity, data is processed and stored on secure servers in Canada; the UK government recognizes Canada as a jurisdiction providing an adequate level of protection for personal data, allowing for the continued free flow of information between the UK and Canada.
8. Cookie Policy Summary
We use cookies to enhance your navigating experience and ensure our clinical platforms function correctly.
- Essential Cookies: Required for secure login and practice management through our partner applications.
- Performance Cookies: Allow us to monitor site health and user interactions anonymously.
- Third-Party Cookies: Set by external booking and financial services to coordinate your sessions.
Your Choices: You can manage, block, or delete cookies via your browser settings at any time.