PRIVACY STATEMENT
Psychology and Gestalt Practice Tanja Mitrovic
Psychology and Gestalt Practice Tanja Mitrovic, located in The Hague, Sweelinckplein 9-11, office 25, and registered with the Chamber of Commerce under number 27350426, values the protection of personal data. This privacy statement explains how Psychology and Gestalt Practice Tanja Mitrovic, with Tanja Mitrovic as the responsible party, handles information about an identified or identifiable natural person, as referred to in the General Data Protection Regulation (GDPR).
1. Scope
This privacy statement applies to the following categories of natural persons whose personal data are processed by Psychology and Gestalt Practice Tanja Mitrovic:
a. (Potential) patients;
b. Visitors to Psychology and Gestalt Practice Tanja Mitrovic;
c. Participants in events organized by Psychology and Gestalt Practice Tanja Mitrovic;
d. Job applicants;
e. All other persons who contact Psychology and Gestalt Practice Tanja Mitrovic or whose personal data are processed by the practice.
2. Processing of Personal Data
Psychology and Gestalt Practice Tanja Mitrovic processes personal data that:
a. The data subject has personally provided (during a meeting or event), by phone, or digitally (via email or web forms on the website), such as contact details or other personal information;
b. Are obtained from other healthcare providers or referrers with the consent of the data subject;
c. Are generated during a visit to the website of Psychology and Gestalt Practice Tanja Mitrovic, such as the IP address, browsing behavior on the website (including data about the first, previous, and current visits, the pages viewed, and navigation on the website), and the sections clicked on;
d. Are recorded through surveillance cameras when visiting the practice premises. Camera images are taken outside the practice, near the elevator, and in the stairwell to track who is present in the building in case of emergencies and to prevent unauthorized access. Camera images are stored and deleted after five days;
e. No video or audio recordings are made during sessions.
3. Purpose of Processing
Psychology and Gestalt Practice Tanja Mitrovic processes personal data for the following purposes:
a. The execution of a medical treatment agreement and billing for services rendered;
b. Submission of Health care type and gb-ggz profile data to health insurances, with the patient’s consent, to comply with legal requirements;
c. Maintaining contact by sending invitations to events and providing requested information;
d. Improving the practice’s website www.tanjamitrovic.nl;
e. Keeping track of user statistics. These statistics provide insight into the number of visitors, duration of visits, the sections of the website viewed, and click behavior. The reports are generic and cannot be traced back to individual visitors;
f. Monitoring access to the practice and protecting confidential data.
4. Legal Basis
Psychology and Gestalt Practice Tanja Mitrovic processes personal data based on one of the following legal grounds:
a. The 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;
b. Execution of or preparation for a medical treatment agreement, including billing to third parties such as health insurance companies;
c. A legal obligation, such as the duty to maintain a medical file or register the Citizen Service Number (BSN);
d. A legitimate interest, such as using contact details to send invitations for an event.
5. Data Processors
Psychology and Gestalt Practice Tanja Mitrovic may engage service providers (processors) to process personal data solely according to its instructions. The practice enters into a data processing agreement with these processors that meets the requirements of the General Data Protection Regulation (GDPR).
6. Sharing Personal Data with Third Parties
Psychology and Gestalt Practice Tanja Mitrovic shares personal data with third parties only when necessary for treatment (such as a referral) or to comply with a legal obligation. The practice does not share personal data with third parties for commercial purposes.
7. Data Transfer Outside the EEA
In principle, Psychology and Gestalt Practice Tanja Mitrovic does not transfer personal data to countries outside the European Economic Area (EEA). If such a transfer becomes necessary, the practice ensures that it only takes place if the European Commission has determined that the country in question provides an adequate level of protection or if appropriate safeguards are in place as defined by the GDPR.
8. Data Retention
Psychology and Gestalt Practice Tanja Mitrovic does not retain personal data longer than necessary. The following retention periods apply:
a. Medical records: at least 20 years after the end of the treatment agreement;
b. (Financial) administrative records: 10 years after data recording;
c. Employee and freelancer records, excluding (financial) administrative data: 5 years after termination of employment or contract;
d. Job applicant records: 6 months after the recruitment process has been completed;
e. Website visitor data: 5 years after the last website visit, unless an objection is made earlier, in which case the data will be deleted.
9. Changes to the Privacy Statement
Psychology and Gestalt Practice Tanja Mitrovic may modify this privacy statement at any time. The most recent version will always be published on the practice’s website. It is advisable to check this privacy statement regularly to stay informed of any changes.
10. Rights, Questions, and Complaints
You have the right to request access to, rectification, deletion, transfer, restriction of, and objection to the processing of your personal data by Psychology and Gestalt Practice Tanja Mitrovic. You can do so by sending an email to info@tanjamitrovic.nl.
For questions or complaints about how your personal data is processed, you can also contact Psychology and Gestalt Practice Tanja Mitrovic via info@tanjamitrovic.nl. We strive to resolve complaints satisfactorily. If this is not possible, you can contact the Dutch Data Protection Authority (Autoriteit Persoonsgegevens - AP).