2. Privacy Policy (GDPR)
2.1. ERIMIS Family Therapy and Systemic Practice abides by strict data protection laws, ensuring client information is confidential and stored securely.
2.1.1. Personal data is processed in accordance with GDPR regulations.
2.1.2. Clients have the right to access, modify, or delete their data, subject to legal limitations.
2.2. Subjects to Privacy Policy (GDPR)
2.2.1. ERIMIS Family Therapy & Systemic Practice is committed to protecting your privacy in accordance with the General Data Protection Regulation (GDPR).
2.2.2. This privacy statement applies to the following categories of individuals whose personal data is processed by ERIMIS Family Therapy and Systemic Practice:
a)(Potential) clients
b)Visitors to ERIMIS Family Therapy and Systemic Practice
c) Visitors to the ERIMIS Family Therapy and Systemic Practice website
d)Participants in ERIMIS Family Therapy and Systemic Practice events
e) Employees of ERIMIS Family Therapy and Systemic Practice
2.3. Privacy of non-emancipated children
2.3.1. ERIMIS Family Therapy & and Systemic Practice do not knowingly collect any Personal Information from children under the age of 16.
2.3.2. If you are under the age of 16, please do not submit any Personal Information through the Website and Services.
2.3.4. If you have reason to believe that a child under the age of 16 has provided Personal Information to us through the Website and Services, please contact us to request that we delete that child’s Personal Information from our Services.
2.3.5. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission.
2.3.6. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission.
2.4 Minors/Guardianship
2.4.1 Non-emancipated Minor Clients
ERIMIS Family Therapy and Systemic Practice provides services to non-emancipated minors (aged below 16) exclusively within the context of family therapy. These services require the explicit consent of the minor’s parents or legal guardians, documented through a signed consent form.
3. Processing of Personal Data
3.1. ERIMIS Family Therapy and Systemic Practice processes personal data when you use our services and when you provide this information to us. The types of personal data processed may include:
a) Contact details (e.g., email, phone number)
b) Personal information shared as part of the registration process or during sessions (e.g., name, address, limited medical information)
c) Camera images from visits to ERIMIS Family Therapy and Systemic Practice, which may be recorded for security purposes in case of emergencies. These images are not stored or used for commercial purposes.
d) Video/audio recordings during sessions or e-health applications (only with the client’s consent).
3.2. Personal data will be stored in a file managed by your therapist.
3.3. This file includes communication from and about you, session notes, and any other relevant information that aids the therapeutic process.
3.4. ERIMIS Family Therapy and Systemic Practice processes your personal data in a secure manner, taking appropriate measures to prevent misuse, loss, unauthorized access, and unwanted disclosure.
3.5. Any personal data provided by you during therapy is handled with the utmost confidentiality.
4. Purpose of Processing Personal Data
4.1. ERIMIS Family Therapy and Systemic Practice processes your personal data for the following purposes:
a. To create and maintain a treatment plan.
b. To handle payments for the services provided.
c. To comply with legal obligations, such as tax reporting.
4.2. ERIMIS Family Therapy and Systemic Practice will only collect personal data necessary for the provision of services, and you have the right to request access, correction, or deletion of your data (with certain legal restrictions).
5. Retention of Personal Data
5.1. ERIMIS Family Therapy and Systemic Practice will retain your personal data for as long as necessary to fulfill the purposes for which it was collected or to comply with legal obligations .
5.2 Therapy notes and treatment-related documents will be deleted after the completion of therapy, unless required for legal reasons:
5.2.1. In line with the Medical Treatment Agreement Act from the Dutch law (WGBO), your file shall be store for 20 years, calculated from the moment of last executed information changed .
5.2.2. Personal data related to financial administration shall be stored for a maximum of 7 years to meet tax obligations.
6. Accessing, Modifying, and Deleting Data
6.1. You have the right to view and modify your personal data.
6.2. You can request access to your file.
6.3. You may add comments or additional information to your file, but you are not permitted to remove information.
6.4. Accessing confidential information provided by others or the therapist’s private notes is not allowed.
6.5. To make a request for accessing or modifying your data, submit a written request with a copy of your ID to ensure privacy protection.
6.6. Appointments for file review will be conducted at the ERIMIS Family Therapy and Systemic Practice office, and photocopies of your file may be made available at a nominal cost.
7. Access to Files in Couples and Family Therapy
7.1. In couples and family therapy, the file may include joint and individual sessions.
7.2. If one partner requests access to the file, the parts related to the individual sessions of the other partner will be temporarily removed unless both parties consent to sharing the full file.
7.3. In family therapy involving children, the file may include individual sessions and correspondence with emancipated children.
7.3.1 Parents have the rights to access the file of their emancipated child(ren) 7.3.1.1 only with their child(ren) consent 7.3.1.2. in line with the legal regulations in the country regarding children rights to privacy.
8. Sharing Personal Data with Third Parties
8.1. The contents of therapy sessions are confidential.
8.2. Information about a client will not be shared with third parties without the explicit consent of the client, except in the following circumstances: a)To comply with a legal obligation .b) If necessary for the execution of the agreement or treatment plan. c) If the data serves as information for educational purpose ( e.g. Intervision-, supervision ) and scientific research and the care provider has adequately anonymized the data.
8.3. ERIMIS Family Therapy and Systemic Practice does not sell personal data to third parties under any circumstances.
9. Confidentiality
9.1.1. Confidentiality is strictly maintained in accordance with professional standards.
9.1.2. Clients are encouraged to communicate via email using a personal, secure account and not through WhatsApp channels ,work related email addresses or unsecured platforms.
9.1.3 Exceptions to confidentiality include instances where there is a risk of harm to oneself or others, or when information must be shared with third parties (with the client’s consent) as part of mediation or family therapy.
9.2. Exceptions to Confidentiality
The exceptions when the professional confidentiality may be breached include:
9.2.1. Duty to Warn and Protect: If a client discloses a plan to harm themselves (e.g., suicide) or others, the therapist is legally obligated to notify appropriate authorities and potentially inform the client’s family.
9.2.2. Child or Vulnerable Adult Abuse: If a client discloses abuse towards a child or vulnerable adult, or if there is a reasonable suspicion of such abuse, the therapist must report this to the relevant social services or legal authorities.
9.2.3. Legal Contracted Obligations: If the client is under the monitorization or protection of law enforcement or any protective organization, ERIMIS may be required to share progress reports with these entities, particularly in cases involving domestic violence, labor exploitation, or human trafficking.
10. Cookies and Similar Techniques
10.1. ERIMIS Family Therapy and Systemic Practice uses cookies to improve your experience on the website.
10.2. These small text files are stored on your device and help us monitor user activity, such as the pages visited.
8.3. Google Analytics may also be used to track visitor behavior in a way that does not identify individual users.
11. Changes to the Privacy Statement
11.1. ERIMIS Family Therapy and Systemic Practice reserves the right to update this privacy policy.
11.2. The most recent version of the privacy statement will be published on ERIMIS Family Therapy and Systemic Practice website.
11.3. The clients are advised to consult the policy regularly to stay informed of any changes.
12. Acceptance of the Privacy Policy
12.1. The client acknowledge that they have read this Policy and agree to all its terms and conditions.
12.2. By accessing and using the Website and Services and submitting information to the service provider, the client agree to be bound by this Policy.
12.3. If the client does not agree to abide by the terms of this Policy, they are not authorized to access or use the ERIMIS Family Therapy and Systemic Practice Website and Services.
13. Fees
13.1. Fee Schedule
For a complete and up-to-date listing of fees, please refer to the “Fees” section on our website.
13.2. Fee Adjustments
Your service provider reserves the right to adjust fees in accordance with inflation or other economic factors.
13.3 Regular Updates
For your convenience, please check the website regularly for any updates or changes to the fee schedule.
14. Payments Execution and Modalities
14.1. Invoicing
At the end of each month, you will receive an invoice for the sessions conducted during that period.
14.2. VAT Exemption.
14.2.1. The session costs are exempt from VAT (BTW-free).
14.3. Payment Method
14.3.1. Payments should be made electronically via internet banking or PayPal, based on the invoice received.
14.4. Payment Deadline
14.4.1. Invoices must be paid within 14 working days of receipt.
14.5. Late Payment and Reminder
14.5.1. If payment is not made by the due date, a payment reminder will be sent every 10 days.
14.6. Service Suspension and Debt Collection
14.6.1. If the overdue payment is not settled within 30 days (after three reminders), ERIMIS Family Therapy and Systemic Practice reserves the right to suspend services and 14.6.2. A third-party agency may be engaged to collect any outstanding debts.
15. Cancellation Policy
15.1. Appointment Reservation
15.2. Once an appointment is booked, the time is reserved exclusively for you.
15.3 Rescheduling or Cancellation Notice
15.4. If you are unable to attend or need to reschedule an appointment, please inform your service provider 48 hours in advance
15.5. Cost-Free Cancellations
15.5.1. Cancellations or rescheduling made with 48 hours’ notice before the scheduled appointment will be free of charge.
15.6. Late Cancellations and No-Show Fee
15.6.1. Cancellations made less than 48 hours before the scheduled appointment, or missed sessions, will incur a no-show fee equivalent to the full price of the booked session.
16. Insurance Policy and Reimbursement
16.1. Healthcare Insurance Contracts
16.1.1. ERIMIS Family Therapy and Systemic Practice is a private and independent practice.
16.1.2. To prioritize confidentiality and independence, ERIMIS Family Therapy and Systemic Practice does not have contracts with healthcare insurance companies.
16.2. Client Responsibility for Payments
16.2.1. Clients are responsible for covering the costs of all sessions.
16.2.2. Payments must be made directly to ERIMIS Family Therapy and Systemic Practice.
16.2.3. Invoices will be issued at the end of each month
16.2.4. Payments should be completed within 14 days of receiving the invoice (see clausa 14.1-14-6)
16.3. Potential Reimbursement for International Insurance
16.3.1. Clients with international health insurance may be eligible for reimbursement.
16.3.2. It is the client’s responsibility to check with their insurance provider regarding coverage and potential reimbursement of therapy costs.
16.4. Tax Deduction for Business Owners
16.4.1.For business owners, the cost of therapy sessions may be deductible as a business expense. For further guidance, clients are encouraged to consult their tax advisor.
17. Crisis Intervention and Therapist Availability in Emergencies
17.1. Non-Emergency Services
ERIMIS Family Therapy and Systemic Practice does not operate as an emergency or crisis intervention service.
17.2. Emergency Support
17.2.1. In case of an emergency, the client is advice to contact his General Practitioner (GP), visit the nearest emergency room, or dial emergency services line (112 for clients residing in The Netherlands).
17.3. Suicide Prevention
In case the client is experiencing suicidal thoughts or thoughts of self-harm, he is urge to contact the Suicide Prevention Hotline ( 113 for clients residing in The Netherlands) or seek immediate support from someone close to him until professional help is available.
18. Competence Limitation and Service Denial
18.1. Exclusion of Certain Conditions
ERIMIS Family Therapy Systemic Practice does not provide services to clients with the following diagnosed conditions:
a) Neurodevelopmental disorders
b) Schizophrenia spectrum and other psychotic disorders
c) Bipolar and related disorders
d) Obsessive-compulsive and related disorders
e) Dissociative disorders
f) Feeding and eating disorders
g) Elimination disorders
h) Sleep-wake disorders
i) Sexual dysfunctions
j) Gender dysphoria
k) Disruptive, impulse-control, and conduct disorders
l) Substance-related and addictive disorders
m) Neurocognitive disorders
n) Personality disorders
o)Paraphilic disorders
p)Medication-induced movement disorders
r) Any other conditions that require clinical attention.
18.2. Referral and Suspension of Service
18.2.1. If, during the course of treatment, the therapist identifies symptoms or conditions as mentioned at 18.1. that fall outside the competence of the service provider which were not known at the time of registration, the client will be referred to a clinical specialist.
18.2.2. Treatment with ERIMIS Family Therapy and Systemic Practice will be suspended until the client receives appropriate care from a qualified professional.
19. Termination of Therapy
19.1. Client’s Right to Terminate
19.1.1.Clients are free to terminate therapy at any time.19.1.2. A statement of reasonable input is desirable but not mandatory.
19.2. Therapist-Initiated Termination
19.2.1.ERIMIS Family Therapy and Systemic Practice reserves the right to terminate therapy in the following circumstances:
a)The Client’s symptoms or complaints fall outside the therapist’s area of expertise.
b) A specialist referral is deemed necessary.
c)The Client fails to adhere to the terms and conditions outlined in the therapy contract.
19.3. Re-Engagement
19.3.1. If therapy is terminated and the Client wishes to return at a later date, the possibility of resuming therapy will be reconsidered. 19.3.2. By consultation with the client he therapist will conclude whether a new contract is required or the continuation of the therapy qualifies under the title of follow up planning and treatment, emerging from the previous contract and assessment .
20. Complaints Procedure
20.1 Commitment to Quality
ERIMIS Family Therapy & Systemic Practice is committed to delivering high-quality care and addressing all complaints with the utmost seriousness and professionalism.
20.2 Initial Discussion
If a client is dissatisfied with the services provided, we encourage them to first discuss their concerns directly with the therapist to seek resolution.
20.3 Independent Complaint Process
Should the issue remain unresolved, the client may contact an independent complaints officer who will guide them through the formal complaint submission and mediation process.
20.4 Steps in the Complaints Process
20.4.1 Submission of Complaint
a) Should the client remain unsatisfied with the initial discussion with the therapist, they may submit their complaint to the designated complaints handling organization.
b) Complaints regarding ERIMIS Family Therapy and Systemic Practice services can be submitted to info@zorgdoenwijsamen.nl
c) Should the client require assistance during this process, they may contact the complaints officer directly for support at the same email address.
20.4.2 Conversation and Mediation
The complaints officer will review the client’s concerns and, if necessary, facilitate a discussion between the client and the therapist to work toward a resolution.
20.4.3 Resolution
Upon completion of the process, the resolution will be communicated to both the client and the therapist.
20.4.4 Escalation to the Disputes Committee
If the issue is not resolved to the client’s satisfaction, they may escalate the matter to the Disputes Committee. The committee will review the case and issue a binding decision.
21. Acceptance of Policy
21.1. By accessing and using the services provided by ERIMIS Family Therapy & Systemic Practice , the client confirms that they have read, understood, and agreed to all the terms and conditions outlined in this policy.
21.2. If the client does not agree with any part of the policy,they are not authorized to use the services provided by ERIMIS Family Therapy and Systemic Practice.
22. Contact Information
For any questions, concerns, complaints, or to exercise your rights under GDPR, please contact us at info@erimisfamilytherapy.com.
ERIMIS Family Therapy & Systemic Practice
Sweelinckplein 9-11, 2517 GK, The Hague, The Netherlands
Phone: +31 (0) 618267208
Email: info@erimisfamilytherapy.com
Website:www.erimisfamilytherapy.com
KvK Number:61818194
