Privacy Policy and Consent to Personal Data Processing
A Message from Anywhere Therapy on Your Privacy
At Anywhere Therapy, your trust and well-being are at the heart of everything I do. I understand that sharing personal information, especially in a therapeutic setting, requires confidence in how that information is handled. This document is designed to clearly explain my commitment to protecting your privacy and to empower you with full understanding and control over your personal data. I want you to feel secure and informed every step of the way.
Introduction
This document outlines my policy for processing personal data and serves as a consent form for clients (hereinafter "the Client") regarding the collection, use, and storage of their personal data. This policy is in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation – GDPR), which applies uniformly across the European Economic Area (EEA), and other relevant data protection legislation.
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Data Controller Information
My Details (Therapist): Nicole Evors, MSc. Business Name: Anywhere Therapy Address: Copenhagen, Denmark (Primary Place of Establishment) CVR/Business ID: [Insert CVR/Business ID here – If you operate as a sole proprietorship in Denmark, you likely have a CVR number. Insert it here. If not, state "Sole Proprietor" or your legal status and remove this line if no formal ID is applicable for your business type.] Email: evors.anywheretherapy@gmail.com Phone: 0415063051 Website: anywhere-therapy.com
Client Information (for filling in by Client):
Phone: …………………………………………………………………………………
Email: ………………………………………………………………………………… -
Purpose and Lawful Basis for Data Processing
I process personal data for the following purposes and on the following lawful bases:
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Provision of Psychotherapy Services and Consultations:
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The primary purpose of my data processing is to enable the proper and effective provision of psychotherapy services and consultations. This includes scheduling appointments, conducting sessions, and maintaining clinical notes essential for your treatment.
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My processing of general personal data (e.g., contact details, appointment times, invoicing information) is based on the necessity for the performance of the contract between me and the Client (GDPR Article 6(1)(b)).
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My processing of special categories of personal data, such as data concerning health (including mental health information) and any other sensitive data voluntarily disclosed by you (e.g., racial or ethnic origin, religious beliefs, sexual orientation), is based on your explicit consent (GDPR Article 9(2)(a)) and the necessity for the provision of health or social care or treatment (GDPR Article 9(2)(h)), always subject to my professional secrecy obligations.
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Administrative and Legal Obligations:
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I may also process personal data for administrative tasks (e.g., billing, general record-keeping, client management) based on legitimate interests (GDPR Article 6(1)(f)), ensuring that your fundamental rights and freedoms are not overridden.
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Furthermore, data may be processed to comply with legal obligations (GDPR Article 6(1)(c)), such as tax regulations, professional body requirements, or for the establishment, exercise, or defense of legal claims (GDPR Article 9(2)(f)).
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Types of Personal Data I Collect
I collect and process the following types of personal data:
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Identification and Contact Data: Your name, phone number, email address.
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Session Data: Dates and times of your appointments, session notes, progress reports, and other information related to your therapeutic process.
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Special Categories of Personal Data: Data concerning your health (e.g., medical history, mental health diagnoses, symptoms, treatment plans), and other sensitive information that you choose to disclose during therapy, as relevant to your treatment.
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Financial Data: Billing information, payment records (though detailed payment card data is typically processed by third-party payment providers, not stored by me).
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Data Sharing and Disclosure
I am committed to maintaining strict confidentiality of your personal data. Your data is generally not disclosed to third parties without your explicit, separate consent.
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Professional Supervision: For the purpose of professional supervision, which is a mandatory ethical requirement for therapists to ensure quality of care, I may discuss anonymized or pseudonymized aspects of client cases with a qualified supervisor. No identifiable personal information that could directly identify you will be shared during such discussions.
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Collaboration with Other Healthcare Professionals: I will only share your personal data, including health data, with your treating physician or other healthcare professionals (e.g., psychiatrists, other therapists) with your specific, explicit, and informed written consent for each instance of sharing. This consent will detail the specific information to be shared and the purpose of sharing, ensuring your full understanding and agreement.
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Internal Personnel: Data may be accessed by individuals integral to my operations (e.g., administrative support, clinic owners, if applicable) only when strictly necessary for the provision of services, administrative tasks (e.g., scheduling, billing), or legal obligations. These individuals are bound by strict confidentiality agreements and the same data protection standards.
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Legal Obligation: Personal data may be disclosed if required by law (e.g., court order, subpoena, or in cases where there is a serious and immediate risk of harm to yourself or others), or if necessary for the establishment, exercise, or defense of legal claims.
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Data Retention Period
I will process your general personal data (e.g., contact details, billing information) for the duration of our contractual relationship and for 3 years following its termination.
Please note that data concerning health and clinical notes will be retained for a longer period as required by applicable national health legislation (e.g., a minimum of 10 years from the date of the last entry in many European countries). This longer retention period is necessary for continuity of care, potential future health needs, and for the establishment, exercise, or defense of legal claims related to the provision of health services.
After the respective retention periods, your personal data will be securely deleted or anonymized.
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Your Rights as a Data Subject
As a data subject under GDPR, you have the following rights concerning your personal data:
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Right to Withdraw Consent: You have the right to withdraw your consent at any time, independently for each processing purpose. Please note that withdrawing consent for the processing of essential data, particularly health data necessary for providing psychotherapy, may impact my ability to continue providing services. I will inform you of any such implications upon withdrawal of consent.
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Right of Access: You have the right to request information regarding what personal data I am processing about you and to obtain a copy of your data.
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Right to Rectification: You have the right to request the correction or completion of inaccurate or incomplete personal data concerning you.
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Right to Erasure ("Right to be Forgotten"): You have the right to request the erasure of your personal data for which there is no longer a lawful reason for processing, subject to my legal retention obligations (e.g., for health records or legal claims).
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Right to Restriction of Processing: You have the right to request the restriction of data processing if the data is inaccurate, incomplete, or if the reason for its processing has ceased, but you don't consent to its erasure.
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Right to Data Portability: You have the right to receive the personal data you have provided to me in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
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Right to Object: You have the right to object to the processing of your personal data based on legitimate interests, including profiling, where applicable.
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Right Not to Be Subject to Automated Individual Decision-Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. (Note: I do not currently engage in such automated decision-making.)
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Right to Lodge a Complaint: If you believe that my processing of your personal data violates GDPR, you have the right to lodge a complaint with the relevant supervisory authority in the Member State of your habitual residence, place of work, or the place of the alleged infringement.
Contact for Data Subject Rights Requests:
To exercise any of your rights listed above, please contact me using the contact details provided in Section 1. I will respond to your request without undue delay, and in any case, within one month of receiving your request.
Supervisory Authority Contact Information (for the Data Controller):
As my primary place of establishment is Denmark, the relevant supervisory authority for complaints directly related to my operations is:
Datatilsynet Carl Jacobsens Vej 35 DK-2500 Valby Denmark Website: www.datatilsynet.dk
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Cancellation Policy
The Client acknowledges that any absence from a session must be excused at least 48 hours in advance via my phone or email. Failure to do so will result in the consultation being charged in full.
Your Agreement and My Commitment
By signing below, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy and Consent to Personal Data Processing, and the Cancellation Policy. I appreciate your trust in Anywhere Therapy and am dedicated to upholding the highest standards of privacy and care in our work together.
Nicole Evors @https://anywhere-therapy.com/
Signatures
In Copenhagen, Denmark, on:
……………………………………… Signature of Nicole Evors, MSc./Therapist
……………………………………… Signature of Client
