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Privacy Policy

Psybrain Customer Privacy Notice

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

  • Contact details
  • What information we collect, use, and why
  • Lawful bases and data protection rights
  • Where we get personal information from
  • How long we keep information
  • Who we share information with
  • How to complain

Contact details

Email

What information we collect, use, and why

We collect or use the following information to provide patient care, services, pharmaceutical products and other goods:

  • Name, address and contact details
  • Gender
  • Date of Birth
  • NHS/HSC/CHI number
  • Next of Kin details including any support networks
  • Emergency contact details
  • Health information (including medical conditions, allergies, medical requirements and medical history)
  • Information about care needs (including disabilities, home conditions, medication and dietary requirements and general care provisions)
  • Test results (including psychological evaluations, scans, bloods, x-rays, tissue tests and genetic tests)
  • Payment details (including card or bank information for transfers and direct debits)
  • Insurance policy details
  • Records of meetings and decisions

We also collect the following special category information to provide patient care, services, pharmaceutical products and other goods. This information is subject to additional protection due to its sensitive nature:

  • Health information
  • Sex life information
  • Sexual orientation information

We collect or use the following personal information to comply with legal requirements:

  • Name
  • Contact information
  • Identification documents
  • Any other personal information required to comply with legal obligations
  • Insurance details
  • Safeguarding information

We also collect the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:

  • Health information

We collect or use the following personal information for information updates, marketing or market research purposes:

  • Names and contact details
  • Marketing preferences
  • Website and app user journey information
  • Personal information used for medical investigations
  • Records of consent, where appropriate

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

  • Names and contact details
  • Addresses
  • Payment details
  • Account information
  • Purchase or service history
  • Customer or client accounts and records
  • Information relating to health and safety (including incident investigation details and reports and accident book records)
  • Correspondence

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide patient care, services, pharmaceutical products and other goods are:

  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
    • For the assessment and treatment of ADHD there is a legitimate reason to collect personal information for consent to treatment and assessment, impact on health to ensure no harm is done due to any underlying conditions. This benefits the person to ensure appropriate diagnosis and management of their condition.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

  • Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information to comply with legal requirements are:

  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Our lawful bases for collecting or using personal information for information updates, marketing or market research purposes are:

  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
    • This is for audit and analysis reasons to ensure we are providing treatment as per guidelines and analysis of target audience.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

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

  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

Where we get personal information from

  • Directly from you
  • Family members or carers
  • Other health and care providers
  • GP

How long we keep information

Data Categories and Retention Periods

Data Retention Table
Data Category Description Retention Period Disposal Action
Contact Information Name, address, email, phone number 6 years from last interaction Secure deletion from all systems
Account Details Usernames, account numbers, profile information 6 years from account closure or last use Permanent removal and anonymisation
Transaction Records Purchase history, payment details (excluding card data) 6 years from transaction date Data purged from financial systems
Correspondence Emails, chat logs, support tickets 6 years from date of communication Erasure from communication archives
Consent Records Consent forms, preferences, opt-in/out 6 years from withdrawal or expiry of consent Records securely destroyed
Complaint/Enquiry Records Details of complaints, investigations, resolutions 6 years from closure of case Complete deletion from case management systems

All personal data will be reviewed regularly, and any data exceeding the 6-year retention period will be disposed of in line with data protection policies and legal requirements. Where data is required for ongoing legal obligations, retention may be extended until those obligations cease.

For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.

Who we share information with

Others we share personal information with

  • Other health providers (eg GPs and consultants)
  • Care providers
  • 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. However, 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, 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);
  • If in England or Wales – the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
  • If in Scotland – we have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.

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