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Dansk Erhvervspsykologi A/S ("Dansk Erhvervspsykologi", "we" or "us") treat your personal data in accordance with the principles and requirements of the Danish Data Protection Act and the General Data Protection Regulation. The purpose of this policy is to inform you, how we specifically treat your personal data, and your rights in connection therewith.
If you have any questions regarding this policy or wish to exercise your personal rights, you can contact Dansk Erhvervspsykologi through the following contact information:
Dansk Erhvervspsykologi A/S
2100 København Ø
E-mail address: firstname.lastname@example.org
What personal data do we process?
We process the following personal data about our clients:
General personal data such as name, CPR number, telephone number, e-mail address, date of birth, and address.
Sensitive personal data, such as health information. This will typically be the condition the client is seeking treatment for. Examples include stress, substance abuse problems, deaths, illness, psychiatric diagnoses, bullying, and challenges within the family.
We also process the following personal data, when we perform tasks for our customers and associated psychologists:
General personal information such as name, telephone number, e-mail address, job title, and signature. In the event of a sole proprietorship or smaller partnerships, information regarding physical address, bank and payment cards, is also processed.
For what purposes, and on what basis, do we process your personal data?
We process the aforementioned personal data about our clients, to ensure the clients receive the correct treatment, hereunder the establishment and maintenance of contact with the client, as well as ensuring that the client is treated by a psychologist with the appropriate qualifications, and is within a reasonable distance of the client’s personal address.
When a client’s course of treatment is terminated, the personal data is used to compile statistics based on aggregated data (where identification of the individual client is not possible), to attain valuable knowledge regarding our clients’ afflictions, with the purpose of developing preventative measures and improving current treatment options. The statistics are disclosed to, among others, our customers and business partners, to guide the concerned parties to better implement preventative measures, as well as our associated psychologists, to improve current therapies.
The judicial basis for the processing of clients general personal data is either:
following a legitimate interest in the events where the client is referred from our customers, after which we then process the clients’ personal information in order to fulfil the agreement we have entered with our customer, as well as for the purpose of contacting the client, to refer them to the appropriate psychological assistance or,
necessary for the compliance of contracts in the events where the client enters an agreement directly with us, as the processing is, in this case, necessary for fulfilment of the agreement, hereunder contacting the client and referral to the appropriate psychological assistance.
The client’s CPR number is processed to the extent of establishing a payment agreement with the client, or if the client’s CPR number is otherwise necessary for Dansk Erhvarvspsykologi to receive payment for their services, e.g. through their health insurance etc.
The judicial basis for the processing of the client’s sensitive personal data is in the General Data Protection Regulation Article 9(2)(h), as the processing is necessary for the purposes of provision of sound and proper treatment of health. See more below, under “Who do we share your data with?”, where this treatment warrant is elaborated.
We process the above mentioned personal data about (and about the contact persons at) our customers and associated psychologists, for the purpose of establishing contact with these, hereunder handling and administration of payment for services provided.
The judicial basis for the processing of personal data about (and about the contact persons at) our customers and associated psychologists, is necessary for contract compliance, as fulfilment of the agreements entered with both our customers and associated psychologists presupposes that we are able to contact these, as well as administer payment for services provided.
Who do we share your data with?
We transfer personal data, hereunder sensitive data, about our clients to a necessary extent, to one (or more) of our associated, independent psychologists, who we determine are suitable to treat the individual client. The transfer occurs, as it is necessary for the provision of sound and proper treatment of health, per the agreement between Dansk Erhvervspsykologi and the client or, Dansk Erhvervspsykolog and the customer (under which the client is employed, or otherwise covered by the agreement). Dansk Erhvervspsykologi is subject to confidentiality under the Danish straffelovs (Criminal Law) § 152 b and psychologist bekendtgørelsens (Executive Order) § 2. All our employees are also bound by confidentiality indefinitely.
We entrust your personal data to the external supplier of our journal system, Supbine IVS, CVR-nr. 37383236, with whom we have duly entered the according data processing agreement with. Supbine is, at all times, subject to our instructions regarding the processing of personal data that they undertake for us, and they maintain a sufficient level of security, hereunder the implementation of appropriate technical and organisational measures, to accommodate the risks that the processing entails.
How long do we store your personal data?
We store personal data about our clients until the relevant psychologist terminates the treatment of the client when any potential bills have been paid, outstanding issues have been clarified and conflicts have been resolved, or if the purpose of the data processing has otherwise been fulfilled or lapsed.
We store personal data about our clients, to the extent of which the data is necessary to comply with our legal obligations including journalføringsbekendtgørelsen (storage of client records for five years) and bogføringsloven (storage of financial records for five years) unless special circumstances exist, in which case we, without undue delay, will inform the subject of registration of the extended retention period.
You can at any time exercise your personal rights, and request access to your personal data stored and/or processed by Dansk Erhvervspsykologi. This includes the right to erasure and the right to correction of inaccurate or incomplete data.
Additionally, you can limit our processing of your personal data, object our processing, and exercise your right to data portability.
Right to complaint
The subject of registration, can at any time issue a complaint to Datatilsynet (The Danish Data Protection Agency) regarding the processing of the personal data of the party in question, through the contact information below:
Borgergade 28, 5.
1300 København K
Tlf. 33 19 32 00