As a psychologist authorized by the Danish Supervisory Board of Psychological Practice I am obligated to collect and process certain data about my clients.
I abide by the rules concerning storage and processing of personal data – this being GDPR, the Danish Act on the Rights and Duties of Psychologists, the Danish Act on Authorization and the Danish Health Care Act. This means, among other things, that I store the personal data of my clients safely and I only collect necessary information.
I do not pass on the personal data of my clients to anyone unless the client has given consent. This might be relevant, if the client wishes to apply for financial reimbursement from their insurance company or share the results of the psychological assessment with a child’s school etc.
Any communication containing personal data is done securely through encrypted channels.
Psychologist Pernille Brunbech controls the data and ensures that personal data is processed and stored securely in accordance with the law.
Psychologist Pernille Brunbech
Telephone: +45- 93 99 72 11
Types of personal data
I am obligated to collect and process the following types of personal data when conducting psychological assessments and counseling:
Ordinary categories of personal data:
- Name, address, e-mail, telephone number and maybe a social security number.
Sensitive personal data:
- Health details
- Video (only when testing children younger than 3 years)
I only collect and store information necessary and relevant to the purposes stated below.
The purpose of collecting and processing personal data:
I process personal data for the following purposes:
- Psychological assessment and counseling in order to provide the most qualified assistance possible.
- Administration and billing.
- Upholding my responsibilities to the law, this being GDPR and the Danish act on the obligation of psychologist to keep records on their clients (”Bekendtgørelse om autoriserede psykologers pligt til at føre ordnede optegnelser” jf. BEK nr. 567 af 19/05/2017).
The right to decline
When I collect personal data directly from the client, the information is provided voluntarily. The client is not obligated to provide the personal data. However, if the client does not wish to disclose his or her personal information, I will not be able to fulfill the purposes stated above, and it will be impossible for me to help.
Any information provided by other parties, for example a child’s school or doctor, is only collected with the explicit consent of the client or guardian.
At our first meeting I will provide information on confidentiality and my obligation to keep a record, as well as information on how I process and store personal data. I will also ask for consent to collect and store personal data on the client in order to conduct a psychological assessment and/or provide counseling.
As a psychologist authorized by the Danish Supervisory Board of Psychological Practice I am dutybound to confidentiality, as stated in the Danish Act on the Rights and Duties of Psychologists §21, stk. 1 and the Danish Criminal Law §152 and §152 c-f.
I am only allowed to share personal data with the client’s consent.
The duty of confidentiality always applies, except in very specific situations, where the client is deemed a danger to himself or others, or if the law demands that I pass on information.
For children under the age of 18 I am obligated to inform the social services if I have serious concerns for a child’s wellbeing (Danish Act on Social Services §153).
If my services are paid fully or in part by others than the client – eg. by an insurance company or the county – I will in some instances have to pass on personal data. This will only be done with explicit consent from the client.
The personal data I store on the client for billing purposes, are shared with payment service providers only to the extent necessary to complete billing and accounting. The payment service providers are working under data processing agreements which ensures that the data is processed and stored securely.
The legal grounds for collecting, processing, and sharing personal data:
- Ordinary personal data is collected, processed, and shared in order to conduct regular patientcare, in compliance with GDPR article 6(1)(c) and (d). Sensitive personal data is collected, processed, and stored in compliance with GDPR article 9(2)(c) and (h).
- Furthermore, I am obligated to process personal data on a client in accordance with the Danish Act on the Rights and Duties of Psychologists and the obligation of Danish psychologists to keep records on their clients, as stated in “Bekendtgørelse om psykologers pligt til at føre ordnede optegnelser” (BEK nr. 567 af 19/05/2017).
- Personal data is only shared with insurance companies when the client has given consent to do so, in accordance with GDPR article 6(1)(a) og 9(2)(a).
The client can withdraw consent
If the client has consented to me collecting and processing personal data, the client has the right to withdraw his or her consent. The client can do so by contacting me personally – please find my contact information above. If withdrawing consent, this will not affect the services provided previously or any sharing of information done before the withdrawal. The withdrawal of consent is only applicable from the time of the withdrawal.
I delete personal data after 5 years
I delete a client’s personal data, when it is no longer necessary to store them in order to fulfill the purposes stated above. As a psychologist authorized by the Danish Supervisory Board of Psychological Practice I am obligated the Danish Act on the Rights and Duties of Psychologists to store my clients’ personal data for 5 years after the last entry to the record. After this the record is deleted/destroyed in accordance with GDPR.
Personal data used for billing purposes are only stored for as long as they are needed for billing and accounting.
The client’s rights
Within the limitations of the law, the client has certain rights concerning his or her personal data. For instance, the client has the right to access, to rectify and to erase personal data. More information on the client’s rights concerning personal data can be found here:
The right to erasure is, however, modified by the obligation of Danish psychologists to keep records on their clients. This states, that a client’s record may not be deleted but only rectified or added to.
If you are dissatisfied by the way I handle personal data, please contact me in order for me to make changes, if possible. Clients are also within their rights to file a complaint with the proper authorities, like the Danish Data Protection Agency. Contact information on the Danish Data Protection Agency can be found at www.datatilsynet.dk
You are always welcome to contact me if you have questions about the way I process and store personal data.