Privacy policy

1. Introduction

1.1 Purpose of this document

Moments Psychology would like to continue to build a relationship with you grounded in trust and confidence. Part of your rights as a client is the right to privacy protection. This document aims to provide practical guidelines to the provisions established by the “Beschering Persoonsgegevens” (Wbp) act, the “Jeugdwet”  and the “Wet op de beroepen in de individuele gezondheidszorg”. 

1.2 Scope

The privacy policy applies to all services provided by Moments Psychology, including the content and functionality of the website www.momentspsychology.nl and applies to the processing of any personal information in the broadest context. 

Processing of any personal information received from the client or other third parties involved is done in the context of health care services, client administration processing, policy developments and improvements, analysis of incidents, and carrying out responsible management duties. 

Personal information can only be stored in a personal record when:

• Consent was given by the client 

• Fulfil legal obligations in the context of good health 

• Required data processing in the interest of a third party or the controller, unless this is a conflict of interest with the client.

  • Some legal examples of this are provisions related to breaking professional secrecy established by the Dutch “Wet Meldcode”, right of access by Inspectors of Healthcare, Youth Healthcare and right of access by Inspectors of Health Care, Youth Health Care inspectors and supervisors WMO in the context of the “Wkkgz”, “WMO” and “Jeugdwet.”

• Vital life interest of the client

1.3 External regulations and sources

Legal Frameworks in scope:

• Wet Bescherming Persoonsgegevens (Wbp)

• Wet op de beroepen in de individuele gezondheidszorg 

• Europees Verdrag voor de Rechten van de Mens (EVRM) Nederlandse Grondwet

• Wet kwaliteit, klachten en geschillen zorg (Wkkgz)

Regulations in scope:

• NIP Professional Code

• “Meldplicht datalekken”

Other relevant documents in scope:

• Regulation (EU) 2016/679 (General Data Protection Regulation) also known as “GDPR”

2. Definitions

Client Informed Consent

Informed consent is a process of communication between you and your health care provider that often leads to agreement or permission for the collection and processing of personal information, care, treatment, or services. Every patient has the right to get information and ask questions before procedures and treatments

Collection of Data

Process of gathering information.

File

Any structured set of personal data about a single patient. , It is accessible according to certain criteria.

Parties involved

The persons who are directly related to personal data collected and stored.

Personal information/ data

Any information related to a specific person.

Processing of data

Any activity related to personal data. These activities can include collecting, recording, organising, storing, updating, modifying, retrieving, consulting, using or disclosing information, protecting and destroying.

Third-person

Any other person that is not the person concerned.

3. Privacy Regulations

It is important to note that in the case of a minor, data collected about his or her parents or legal guardians also fall under these regulations.

3.1 Collecting and processing information

Prior to collecting any information, Moments Psychology will inform the client about the purpose of collecting and processing information. Moments Psychology will always communicate on one of the official communication platforms. 

All personal information collected will be collected, processed and stored in an appropriate and attentive manner that is in accordance with all the above-mentioned laws and regulations. The following data can be collected via the website:

• Name,

• Email Address

• Telephone Number  

An additional registration form will be sent upon commencement of therapy in the context of good healthcare. The following data can be collect:

• Name,

• Date of birth

• Residential Address

• Telephone number

• Email Address

• Contact information in case of an emergency (relative or friend, as well as your general practitioner)

In the case of minors, additional information will be collected from the parents or legal guardians.

This information is collected and saved in the password-protected document in an online server. The personal information collected will only be processed for health care purposes, except in the case of deviating legal obligations. The client will be informed about any additional information from somebody other than the client or their legal guardian as well as the context in which it was received.  

3.2 Disclosing personal information

Any personal information will only be disclosed to third persons if the client is informed. Moments psychology can provide information in accordance with the law. In principle, the next of kin have no right to access any personal data. In the case of information being disclosed without prior consent given by the client, Moments Psychology must immediately inform the client or his/her legal representative unless this is dangerous for the persons involved or property.  

3.3 Access and protection of personal information

Only Vernandi Dyzel and other management support staff have access to personal information. Management support staff only has access to this information in order to ensure that information is stored securely and effectively. All members mentioned previously are required to maintain confidentiality. Personal information is anonymised as much as possible. It is required that personal information be stored for a period of 15 years, destruction will take place within three months after this period is completed. Upon written request of the client, personal information can be transferred to other healthcare professionals. The client has the responsibility to follow up on the privacy statement of the new healthcare provider.  

3.4 Client rights and privacy data

The client has the right to inspect and request a copy of their personal data. This request should be written and accompanied by a copy of an identification document. This request will be processed within four weeks from receiving the request. A request for access, information or copy may be denied if the client’s rights and third parties’ freedoms are jeopardized. The client has the right to request the destruction or alteration of any information that is false or incorrect. This information should be supplemented with the correct information. This request should also be written and supplemented by a copy of an identification document. During the storage period, a client may request that all information concerning him or her be destroyed. Unless it is reasonably plausible that the retention of the data is of considerable interest to another party other than the client, as well as and to the extent that the retention is required by statutory regulation, the data will be destroyed. By way of derogation from the aforementioned, the destruction of data will then take place after the client has fulfilled all payment obligations; this request should also be written and supplemented by a copy of an identification document. 

3.5 Establishing and amending the regulations

These regulations were adopted on 01-11-2020 by Moments psychology. In all cases not provided for in these regulations, the provisions of the Wbp apply.