Privacy Notice

Mentina Therapies Limited (16369593) is registered as data protection compliant with the Information Commissioner’s Office (ZB898674). It adheres to current data protection legislation, including the General Data Protection Regulation (EU/2016/679) (GDPR), the Data Protection Act (2018) and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

This privacy notice tells you what to expect us to do with your personal information.

Contact Details

You can contact us for any reason via email contact@mentinatherapies.com or via the contact us section on the website www.mentinatherapies.com; either at the bottom of the home page, or under the contact us section, which you can find in the header.

The Clinical Director of Mentina Therapies Limited is Dr Jenny Lisshammar.

Information we collect, use, and why.

You clinician keeps notes of all your psychology sessions. The keeping of full, clear, and accurate records are a requirement of the Health and Care Professions Council, and the British Association of Behavioural and Cognitive Psychotherapists. We also keep a record of all communication with or about you, with a Mentina Therapies representative. This includes email, letter, and telephone contacts. This makes up your clinical record, and is a confidential document under the common law duty of confidentiality.

Mentina Therapies Limited collects and uses the following information to provide patient care.

This may include onward referral to other services or organisations, either as per your agreement with your clinician (only with your consent) or else in the case of risk of harm to you or someone around you – see our confidentiality policy. Not all of these may apply to you.

• (A) Your first and last name To provide patient care, hold a clinical record for you, and to be able to communicate with you.
• (B) Your date of birth To be able to identify you in onward referrals to other healthcare providers or organisations whose involvement in your care is necessary, justified, and proportional. This may either be with your consent, or due to our duty of care to keep you and those around you safe. See “who we share your data with” and the confidentiality policy.
• (C) Your home address To be able to identify you in onward referrals to other healthcare providers or organisations whose involvement in your care is necessary, justified, and proportional. This may either be with your consent, or due to our duty of care to keep you and those around you safe. See “who we share your data with” and the confidentiality policy.
• (D) Your GP information To be able to contact your GP in case of need for onward referral to them for urgent psychological support, risk-management, or other health reasons.
• (E) Your email address and your telephone number. To be able to contact you to arrange and manage sessions and facilitate your contact with Mentina Therapies.
• (F) Next of Kin details: name and telephone number To be able to contact someone around you in case of immediate concern about your safety and wellbeing, or the safety and wellbeing of somebody around you. This would only be in instances were our duty of care to keep you and those around you safe, applies. See “who we share your data with” and the confidentiality policy.
• (G) Insurance Policy Details To be able to invoice your insurance company for your sessions as instructed.
• (H) Records of therapy sessions & records of any communication with or about you, and Mentina Therapies Limited. Full, clear, and accurate records are a requirement of the Health and Care Professions Council.

We also collect the following special category information to provide patient care:

• (A) Health information This, for the purpose of maintaining a full, clear, and accurate clinical record.

We collect or use the following personal information for dealing with queries, complaints, or claims:

• (A) Name and contact details (email, telephone number) To be able to communicate with you, and identify communication from you as belonging to you. To be able to contact you to book, cancel, or rearrange sessions, as well as liaise with you about topics directly related to our therapy work together, such as onward referrals.
• (B) Your Payment Details If we need to process a refund to you. These are not kept on file after the refund has been processed.
• (C) Your clinical record If we need to review an event that has occurred during your contact with Mentina Therapies Limited.
• (D) Records of any communication with or about you, and Mentina Therapies Limited. If we need to review an event that has occurred during your contact with Mentina Therapies Limited.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide patient care are:

Article 9(2)(h) Healthcare provision

Your information is processed to provide psychological assessment, therapy, and ongoing care, and to manage healthcare services. All of your data protection rights may apply, except the right to erasure and right to data portability. These limitations only apply where necessary and proportionate.

Article 9(2)(c) Vital interest

Your information may be processed where necessary to protect your vital interests or those of another person. For example, in a medical emergency or where there is a serious and immediate risk to life. All of your data protection rights may apply, except the right to erasure, right to data portability, right to object, and right to restriction. These limitations only apply where necessary and proportionate.

Article 9(2)(g) Substantial public interest

Your information may be processed or shared where necessary for reasons of substantial public interest, such as safeguarding a child (under the age of 18) or an adult at risk (see confidentiality policy), preventing serious harm, or meeting legal obligations. All of your data protection rights may apply, except the right to erasure, right to data portability, right to object, and right to restriction. These limitations only apply where necessary and proportionate.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

Article 6(1)(c) Legal obligation

We may process your personal information where it is necessary to comply with a legal obligation, such as responding to formal complaints, regulatory requirements, or legal proceedings. Some of your data protection rights may be limited where applying them would prevent us from complying with our legal obligations. All of your data protection rights may apply, except the right to erasure, right to object, and right to restriction.

Article 6(1)(f) Legitimate Interest

We may process your personal information where it is necessary for our legitimate interests, including managing and responding to queries, complaints, or claims, and protecting our legal rights. You have the right to object to this processing. However, we may continue to process your information where we can demonstrate compelling legitimate grounds that override your rights, or where processing is necessary for the establishment, exercise, or defence of legal claims.

Where we get personal information from

• Directly from you
• Other health and care providers; only in emergency situations or where you have consented to data sharing.

How your personal information is stored

Your information is stored on a secure, password-protected, GDPR-compliant online platform called Cliniko. Cliniko is a designated clinical practice management software.

You can read more about our chosen practice management software, here.

Your personal information, together with your clinical notes, make up your clinical record.

How long we keep information

For all individuals who become a client of Mentina Therapies Limited, their information is stored for seven years from the date of last contact. For all individuals who have enquiry-level contact with Mentina Therapies Limited, but do not access its services, become its client, agree to its terms and conditions, or express any concerns or complaints to or about it or any person associated with it, information is stored for six months from last contact, to facilitate resolution of that contact. If you raise a concern or complaint about Mentina Therapies limited or any person associated with it, this record is stored for seven years from the date of mutually agreed resolution of this concern or complaint. This, on the legal basis of legitimate interest.

In the event of your death

Confidentiality continues after death. While UK data protection law applies only to living individuals, we remain bound by the common law duty of confidentiality and professional standards. Requests for access to records after death will be considered carefully and may be granted to authorised individuals in accordance with the Access to Health Records Act 1990.

You may express preferences about how your information is shared, including after your death. We will take these wishes into account wherever possible. However, confidentiality cannot be guaranteed in all circumstances, and information may still be disclosed where there is a legal obligation or where there are overriding public interest considerations.

Who we share information with

Data processors

Psych VA Ltd.

This data processor does the following activities for us: Administrative activities; email correspondence, appointment scheduling, invoicing. They are bound by the common law duty of confidentiality.

Others we may share personal information with

• Other health providers (e.g. GPs and other medical professionals involved in your care)
• Insurance companies, brokers and other intermediaries
• Charities and voluntary organisations
• Organisations we need to share information with for safeguarding reasons
• Emergency services
• Organisations we’re legally obliged to share personal information with

Duty of confidentiality

We are subject to a common law duty of confidentiality. This is a legal obligation which requries healthcare professionals to keep information that you shared in confidence, private, unless there is a valid legal or ethical reason to disclose it. There are circumstances where we will share relevant health and care information. These are where:

• You’ve provided us with your consent (we have taken it as implied to provide you with care, or you have given it explicitly for other uses);
• We have a legal requirement (including court orders) to collect, share or use the data;
• On a case-by-case basis where the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime).

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice. If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint