Privacy Policy — Groundwork Psychotherapy

Faidra Papanikolaou, Psychologist (MSc)

Kvægtorvsgade 1, kld., 1710 København V, Denmark

Email: groundwork_psychotherapy@proton.me | Phone: +45 52 90 75 30

Processing of your information

As data controller in connection with your psychological treatment, I am obligated to collect and process a range of personal data about you, in accordance with the Danish Psychologist Act (Psykologloven) and the Executive Order on Organized Records for Psychologists. This privacy policy describes how I use, and in some cases disclose, your personal data in this context.

Types of information collected

Groundwork Psychotherapy collects and processes the following categories of personal data about you, to the extent relevant:

General categories: name, address, email address, phone number, personal identification number (CPR, where applicable), gender, family relations and social relationships, occupational relationships and education.

Special categories ("sensitive personal data"): health information, including information shared during therapy sessions.

Purpose of processing

Your personal data is processed for the following purposes: providing psychological treatment to you; preparing certificates for use by authorities, insurance companies, etc.; communication with other healthcare professionals, doctors, or hospitals, where relevant to your care; billing purposes; and compliance with obligations under applicable law, including the EU General Data Protection Regulation (GDPR), the Danish Data Protection Act, and other relevant health legislation, including documentation duties and the implementation of technical and organizational security measures.

Voluntary provision of information

When I collect personal data directly from you, you provide this data voluntarily. You are not obligated to provide this information. However, if you choose not to, I may not be able to provide the treatment described above.

Disclosure of personal data

To the extent necessary for your treatment, your personal data may be disclosed to: other healthcare professionals, where necessary for your ongoing treatment; the Danish Patient Safety Authority (Styrelsen for Patientsikkerhed) or the Psychology Board (Psykolognævnet), where required by law; and insurance companies, but only with your prior consent.

You, as the client, have a right of access to your own data at any time.

The legal basis for collecting, processing, and disclosing your personal data is Article 6(1)(c) and (d) GDPR for general personal data, and Article 9(2)(c) and (h) GDPR for sensitive health data, together with the Danish Psychologist Act and the Executive Order on psychologists' record-keeping obligations. Where disclosure is based on consent, this occurs under Article 6(1)(a) and Article 9(2)(a) GDPR.

Withdrawal of consent

Where processing of your personal data is based on consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

Use of data processors

Your personal data is stored and processed by data processors acting on my behalf and instructions. My current data processors include secure IT and email service providers, such as Proton Mail, which offers end-to-end encryption and EU-based data storage, and any practice management or billing systems used in the clinic.

Retention and deletion policy

I retain your personal data for as long as necessary to fulfil the purposes described above. Under the Danish Executive Order on record-keeping (journalføringsbekendtgørelsen § 15), I am required to retain your records for a minimum of 5 years after the last entry in your file. Longer retention may apply in the event of a complaint or liability case, until that matter is fully resolved.

Your rights

Subject to certain legal limitations, you have the right to: access your personal data; have inaccurate data corrected; request erasure of your data; request restriction of processing; data portability; and object to processing, including automated decision-making ("profiling").

Note that your right to erasure is limited by the Executive Order on psychologists' record-keeping, which prohibits deletion of entries in client records — only corrections or additions may be made.

You also have the right to lodge a complaint with a competent supervisory authority, including the Danish Data Protection Agency (Datatilsynet).

Contact

If you have questions about the processing of your personal data or wish to exercise your rights, please contact me at groundwork_psychotherapy@proton.me or +45 52 90 75 30.