Psychologiepraktijk Michiel Eebes, based in Groningen and registered with the Netherlands Chamber of Commerce (KvK) under number 97316148, attaches great importance to the protection of personal data. This privacy statement explains how Psychologiepraktijk Michiel Eebes handles information about an identified or identifiable natural person, as referred to in the General Data Protection Regulation (GDPR, in Dutch: AVG).
This is a translation of the Dutch privacy statement. In case of any discrepancy, the Dutch version prevails.
1. Scope
This privacy statement applies to the following categories of natural persons whose personal data Psychologiepraktijk Michiel Eebes processes:
- (prospective) clients;
- visitors to the practice;
- visitors to the website michieleebes.nl;
- all other persons who contact the practice or whose personal data the practice processes.
2. Processing of personal data
Psychologiepraktijk Michiel Eebes processes personal data that:
- a data subject has provided personally (during a conversation), by telephone or digitally (by email or via the contact form on the website), such as contact details or other personal data;
- are obtained from third parties, such as the referring GP or other care providers;
- are recorded in the electronic client file for the purpose of treatment, including data about your health, and data processed when using eHealth applications and digital questionnaires that support treatment;
- may be processed for technical reasons during a visit to the website, such as the IP address. The website does not use tracking or marketing cookies and does not track individual browsing behaviour.
3. Purposes of processing
Psychologiepraktijk Michiel Eebes processes personal data for the following purposes:
- carrying out a medical treatment agreement and billing for work performed;
- managing the practice, including quality purposes and the handling of complaints and/or claims;
- maintaining contact and providing information that a data subject has requested;
- the proper functioning and improvement of the practice website michieleebes.nl.
4. Legal basis
Psychologiepraktijk Michiel Eebes processes personal data on the basis of one of the following legal grounds:
- consent of the data subject. This consent can be withdrawn at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
- the performance of — or with a view to entering into — a medical treatment agreement, including billing third parties such as the health insurer;
- a legal obligation, such as the obligation to keep a medical record or to register the citizen service number (BSN);
- the protection of the vital interests of the data subject or of another natural person;
- a legitimate interest, such as the use of contact details for practical communication regarding treatment.
5. Processors
Psychologiepraktijk Michiel Eebes may engage service providers (processors) to process personal data, who process personal data solely on the instructions of the practice, such as the supplier of the electronic client file. A data processing agreement is concluded with processors that meets the requirements of the General Data Protection Regulation (GDPR).
6. Sharing personal data with third parties
Psychologiepraktijk Michiel Eebes does not share personal data with third parties without the consent of the data subject, unless this is appropriate in the context of carrying out the treatment agreement or managing the professional practice, or is necessary to comply with a legal obligation. Examples include sharing data with the health insurer and the Dutch Healthcare Authority (NZa), or access to the file by a BIG-registered professional bound by professional secrecy in the context of quality audits. Explicit written consent from the client is not required for the latter; the client does, however, have the option to object to the use of their data for quality purposes. To that end, the client is informed in advance of the possibility that their data may be used for these quality purposes. The practice does not share personal data with third parties for commercial purposes.
7. Transfer outside the EEA
In principle, Psychologiepraktijk Michiel Eebes does not transfer personal data to countries outside the European Economic Area (EEA). Should this nevertheless be necessary, the practice will ensure that the transfer only takes place if the European Commission has stated that the country concerned offers an adequate level of protection, or if appropriate safeguards are in place within the meaning of the General Data Protection Regulation (GDPR).
8. Retention of data
Psychologiepraktijk Michiel Eebes does not retain personal data longer than necessary. In principle, the following retention periods apply:
- Medical data — at least 20 years after the end of the treatment agreement (in accordance with the Dutch Medical Treatment Contracts Act, WGBO);
- (Financial) administrative data — 7 years after the data were recorded;
- Other contact details and correspondence — no longer than necessary for the purpose for which they were provided.
9. Changes to this privacy statement
Psychologiepraktijk Michiel Eebes may amend this privacy statement at any time. An up-to-date version is published on this website. It is advisable to consult this privacy statement regularly, so that you are aware of any changes.
10. Rights, questions and complaints
You have the right to ask Psychologiepraktijk Michiel Eebes to access, rectify, erase or transfer personal data, to restrict processing and to object to processing. You can do so by sending an email to info@michieleebes.nl.
If you have questions or complaints about the way the practice processes personal data, you can also contact info@michieleebes.nl. I will try to resolve a complaint to your satisfaction. If that does not succeed, you can turn to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, AP).