Legal
Privacy Policy
Last updated: February 2024
1. Introduction
PsychiatristAI ("we", "our", or "us") is committed to protecting the privacy and security of personal data, particularly special category health data processed through our clinical decision support platform. This Privacy Policy explains how we collect, use, store, and protect your information in compliance with UK GDPR, the Data Protection Act 2018, and NHS information governance standards.
2. Who We Are
Data Controller: PsychiatristAI Ltd
Registered Office: [Address to be completed]
Company Number: [Number to be completed]
ICO Registration: [Number to be completed]
Contact: privacy@psychiatrist.ai
Where we process health data on behalf of NHS Trusts or other healthcare organizations, we act as a Data Processor. The NHS Trust or healthcare organization remains the Data Controller.
3. What Data We Collect
Clinical Data (Special Category)
- Patient demographics (pseudonymized where possible)
- Clinical observations and assessments
- Mental health diagnoses and symptoms
- Medication records
- Risk assessments and safeguarding information
- Clinical documents (referral letters, discharge summaries, tribunal reports)
Healthcare Professional Data
- Name, job title, and professional registration number
- Work email and contact details
- Login credentials (hashed and encrypted)
- Audit logs of system activity
Technical Data
- IP addresses and device identifiers
- Browser type and version
- Access timestamps and session duration
- System performance and error logs
4. Legal Basis for Processing
We process personal data under the following legal bases:
- •Article 6(1)(e) UK GDPR: Performance of a task carried out in the public interest (provision of healthcare services)
- •Article 9(2)(h) UK GDPR: Health or social care purposes, including the management of health or social care systems and services
- •Article 9(2)(j) UK GDPR: Archiving, research, and statistical purposes (where applicable, with appropriate safeguards)
All processing is conducted in accordance with NHS Information Governance standards, the Caldicott Principles, and the common law duty of confidentiality.
5. How We Use Your Data
Direct Care Purposes:
- Recording and tracking patient observations
- Generating clinical summaries and reports (discharge, tribunal, CPA)
- Supporting clinical decision-making and risk assessment
- Facilitating multidisciplinary team communication
- Medication management and safety monitoring
Service Management:
- Clinical audit and quality improvement
- Compliance monitoring (CQC, observation schedules)
- Service planning and resource allocation
- Staff performance and training (aggregated, anonymized)
System Operations:
- Security monitoring and incident response
- System troubleshooting and performance optimization
- Audit trail maintenance for governance
6. Data Sharing and Third Parties
We do not sell, rent, or share patient data with third parties for marketing purposes.
We may share data with:
- •Healthcare providers: GPs, community mental health teams, and other NHS services involved in patient care (with lawful basis)
- •NHS infrastructure providers: NHS Digital, NHS X (for integration with Spine, Summary Care Record, etc.)
- •Cloud service providers: AWS/Azure (UK-hosted, GDPR-compliant data processing agreements in place)
- •Regulators: CQC, ICO, NHS England (when legally required)
All third-party processors are bound by Data Processing Agreements (DPAs) and must comply with UK GDPR standards.
7. Data Security
We implement robust technical and organizational measures to protect your data:
- Encryption at rest (AES-256) and in transit (TLS 1.3)
- Role-based access control (RBAC) with multi-factor authentication
- Regular penetration testing and vulnerability assessments
- ISO 27001 certified information security management
- Cyber Essentials Plus certification
- 24/7 security monitoring and incident response
- Regular staff security awareness training
- Secure backup and disaster recovery procedures
8. Data Retention
Data retention periods are determined in collaboration with the NHS Trust or healthcare organization:
- Clinical records: Retained per NHS Records Management Code of Practice (typically 8-20 years post-discharge)
- Audit logs: Minimum 6 years (longer if required for litigation)
- System performance logs: 90 days (unless required for incident investigation)
- Anonymized/pseudonymized research data: As per study protocol and ethical approval
Data is securely destroyed at the end of the retention period using certified data destruction methods.
9. Your Rights
Under UK GDPR, you have the following rights:
🔍 Right to Access
Request a copy of your personal data
✏️ Right to Rectification
Correct inaccurate or incomplete data
🗑️ Right to Erasure
Request deletion (subject to legal obligations)
⛔ Right to Restrict Processing
Limit how we use your data
📦 Right to Data Portability
Receive your data in a structured format
🚫 Right to Object
Object to certain processing activities
Important: Some rights may be limited where processing is necessary for direct care, public health, or legal compliance. Requests should be directed to your healthcare provider's Data Protection Officer in the first instance.
10. Cookies and Tracking
Our website and platform use cookies for the following purposes:
- Essential cookies: Required for login, session management, and security (cannot be disabled)
- Functional cookies: Remember preferences and settings (can be disabled)
- Analytics cookies: Understand how users interact with the platform (anonymized, can be disabled)
We do not use third-party advertising or tracking cookies. You can manage cookie preferences via your browser settings.
11. Children and Vulnerable Adults
PsychiatristAI processes data for patients of all ages, including children and young people (under 18) and vulnerable adults. Additional safeguards are applied:
- Parental/guardian consent obtained where appropriate
- Enhanced safeguarding risk flags and monitoring
- Adherence to Gillick competence principles for consent
- Compliance with Children Act 1989 and Care Act 2014 information-sharing duties
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in law, regulation, or our practices. The "Last updated" date at the top of this page will indicate when the latest version was published. We will notify NHS Trusts and healthcare organizations of material changes.
13. Contact Us
For questions, concerns, or to exercise your data rights, please contact:
PsychiatristAI Data Protection Officer
Email: dpo@psychiatrist.ai
Address: [Address to be completed]
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):ico.org.uk