Note: The Dutch version of this disclaimer is given preference at all times as to the interpretation thereof. See https://www.empower-pt.nl/privacystatement/
Privacystatement Empower Psychotherapie B.V.
Empower Psychotherapie B.V. established in Groningen and registered with the Chamber of Commerce under number 66184525, hereinafter “Empower” attaches importance to the protection of personal data. This privacy statement explains how Empower handles information about an identified or identifiable natural person, as referred to in the General Data Protection Regulation (GDPR).
This privacy statement applies to the following categories of natural persons whose Empower processes personal data:
- (potential) clients;
- visitors to Empower’s practice;
- visitors to the website empower-pt.nl;
- participants in meetings of Empower;
- any other persons who contact Empower or whose Empower processes personal data, with the exception of its employees.
Processing of personal data
Empower processes personal data that:
- a person concerned has provided personally (during a meeting or discussion), by telephone, or digitally (via e-mail, web forms on the website or other means), such as contact details or other personal data;
- with the permission of the person concerned being requested from other care providers or referrers;
- provided to us by other persons or bodies, such as a referring general practitioner, or insurers;
- during a visit by a person concerned to the website of Empower are generated, such as the IP address, the surfing behavior on the website (such as data about the first visit, previous visit and current visit, the pages viewed and the way in which the website is used. navigated) and on which parts the person concerned clicks.
Empower processes personal data for the following purposes:
- the execution of a medical treatment agreement and the declaration for work performed;
- maintaining contact, invitations for meetings and information requested by the person concerned;
- improving the website empower-pt.nl;
- tracking user statistics. User statistics of the website provide information about the number of visitors, the duration of the visit, which parts of the website are being viewed and the click behavior. It concerns generic reports that are not traceable to individual visitors;
- protecting confidential data.
Empower processes personal data on the basis of one of the following principles:
- consent of the person concerned. This permission can always be withdrawn, without affecting the lawfulness of the processing on the basis of the permission before the withdrawal;
- execution of – or with intent to fulfill a medical treatment agreement, including the declaration to third parties, such as the health insurance company and the like;
- a legal obligation, such as the obligation to keep a medical record or to register the BSN;
- a legitimate interest, such as the use of contact information for inviting someone to a meeting.
Empower can use service providers (processors) to process personal data that process personal data only in accordance with Empower’s instructions. Empower concludes with processors a processor agreement that meets the requirements set by the General Data Protection Regulation (GDPR).
Share personal data with third parties
Empower shares personal information with third parties, if this is indicated in the context of the treatment (for example a referral) or if it is necessary to comply with a legal obligation. Empower does not share personal data with third parties for commercial purposes, unless meetings are organized together with another organization. In that case, only necessary contact information is shared.
Transfer outside the EEA
Empower does not, in principle, transfer personal data to countries outside the European Economic Area (EEA). If this should nevertheless be necessary, Empower ensures that the transfer only takes place if the European Commission has indicated that the country in question offers an adequate level of protection or if there are appropriate safeguards within the meaning of the General Data Protection Regulation (GDPR).
Storage of data
Empower does not store personal data longer than necessary. In principle Empower applies the following retention periods:
- medical data: at least 15 years after the end of the treatment agreement;
- (financial) administrative data: 7 years after recording the data;
- data of employees and freelancers, other than (financial) administrative data: 5 years after termination of employment or after the end of the assignment agreement;
- details of applicants: 6 weeks after completion of the application procedure, unless objection is made earlier in which case the cancellation will be proceeded, unless longer if the applicant explicitly gives permission to keep the application, for example for future vacancies;
- visitors to the website: 5 years after the last visit to the website, unless a previous objection is made in which case destruction will be proceeded.
Changes to privacy statement
Empower can always change this privacy statement. A current version of the privacy statement is published on the Empower website. It is advisable to consult this privacy statement regularly so that you are aware of any changes.
Rights, questions and complaints
You have the right to request Empower to view, rectify, delete, transfer, limit processing and object to processing. You can contact Empower by sending an e-mail to firstname.lastname@example.org.
Also in case of questions or complaints about the way in which Empower processes personal data, you can contact Empower by sending an e-mail to email@example.com. We try to resolve a complaint satisfactorily. If that does not work, you can contact the Dutch Data Protection Authority (AP).
Version May 22, 2018