Privacy statement Balanskompass

General Terms and Conditions

Services

a. The counselor provides personal services to companies and private individuals. These services are set out in a proposal approved by the client and the commissioning party. The guiding principles are that the counselor acts with integrity in accordance with the RBCZ professional code (see https://rbcz.nu/wp-content/uploads/2023/02/PR-200-Beroepscode-inclusief-leeswijzer.pdf) and that the interests of the client are central.

b. The nature of the services is explanatory and aimed at personal awareness and change. The client chooses whether or not to apply this awareness and change in their personal situations. The intended change is defined in a counseling request and incorporated into the proposal.

c. For both the exchange of information and personal services, it is assumed that the client is physically and mentally healthy, possibly with a temporary issue or physical complaint, or with a need for guidance in personal development, and has an affinity with the counselor’s philosophy. It is also assumed that clients have no physical or psychological limitations preventing participation. If in doubt as to whether these conditions are met, the client must take the initiative to consult a person they deem competent to determine whether receiving, applying the information, and/or using the counselor’s services is appropriate for them. The client is also expected to report any doubts to the counselor in advance, as well as any doubts that arise during contact.

d. The counselor reserves the right to decline entering into a service relationship with a client. It may also occur during the provision of services that the counselor considers it preferable to refer the client elsewhere or, for other reasons, to terminate the service relationship. As a general principle, however, any problems are regarded as an integral part of the process and are treated as such.

e. The counselor assists clients to the best of her knowledge in gaining greater insight into their competencies and personal functioning. The counselor undertakes to make every reasonable effort within the framework of the company philosophy. The client is at all times responsible for providing accurate and complete information about themselves and their physical and mental condition, for making responsible choices, and for implementing those choices.

f. If clients are referred by the counselor to other persons, companies, physicians, information sources, etc., this is done based on the knowledge available at that time. All contacts with such persons, companies, or physicians, any services provided or obtained, consultation of information sources, and the consequences thereof fall outside the responsibility of the counselor. The counselor assumes that the client will use sound judgment to assess the suitability, qualifications, reliability, and conditions of such third parties.

g. Current prices for services are determined in consultation. Agreed prices for long-term business engagements apply at most until the end of the calendar year following the signing of the assignment and may be revised thereafter. Timely communication will take place regarding any revisions. Government-imposed financial measures are payable from the moment they take effect and cannot constitute grounds for terminating the agreement.

h. Appointments may be rescheduled or canceled free of charge up to 48 hours before the session. Appointments with the counselor are binding once mutually confirmed by both counselor and client. For all counseling sessions with private individuals and companies, appointments not canceled or rescheduled at least 48 hours prior to the session will be charged in full.

If the counselor is required to travel for an appointment and the session cannot take place due to force majeure after the counselor has already arrived at the location, the client is required to pay the travel expenses in the form of the applicable mileage allowance.

j. Termination of a program. If sessions are agreed upon for an indefinite period, the notice period is one session, which will serve as the final evaluation and closing session. If sessions are agreed upon for a fixed period and are terminated prematurely, the amount for the remaining sessions will be refunded upon request, minus one session (1.5 hours) as an administrative fee. This article does not apply to so-called Balance Packages; no refund is possible upon termination of such programs. In cases of urgent necessity to terminate the agreement, as referred to in the general provisions Article 5, paragraph b, no refund will be made.

Confidentiality

a. The name, address, and other personal data, as well as contact details of clients, whether or not related to a corporate client, are used by the counselor for recording payment obligations and for normal communication purposes. Client data will not be made available to third parties, not even when the commissioning party is the employer. The practice operates in accordance with the RBCZ professional code as stated above.

b. Given the generally short-term nature of the contacts, extensive file formation is not maintained. Any personal records are accessible only to the counselor and the respective client, regardless of who pays for the services. Access may also take place during personal contact between counselor and client.

c. Experiences gained by the counselor during client contacts may be incorporated into communications and professional exchanges with colleagues in such a way that it cannot reasonably be determined which client was involved. Clients may object in writing within one month of entering into the agreement and/or immediately after becoming aware of such publication.

d. This counselor does not report about clients to institutions or companies such as the UWV, occupational/health physicians, or insurers, even if explicitly requested to do so by the client.

Payment and Donations

a. Prices and payment terms are communicated in advance. The client pays the counselor per session or per program. The agreed amount is payable immediately after the session (via payment request or cash) or within 14 days of the invoice date, unless otherwise agreed. Donations without a specific service in return are welcome; however, they cannot subsequently be designated as payment for any form of service.

b. If payment is not made within 14 days, the client is in default and the counselor may charge 1% interest per month without further notice of default. After 14 days, the counselor is entitled to send a payment reminder, for which €10 may be charged. If payment is still not received within 7 days after the reminder, the counselor is entitled to initiate collection proceedings. The costs of collection measures are borne by the client. All such measures must be taken in good faith and in accordance with principles of reasonableness and fairness.

Any damage to the counseling process caused by non-payment should be limited as much as possible by both counselor and client.

Guarantee

a. Due to the nature of the services and the explicit involvement of the client in the process of awareness and change, the counselor does not guarantee success or prospects of improvement. The client determines whether and how quickly change occurs. Based on past experience, insight into natural processes, and the client’s personality, an interim estimate of expected development may be provided.

b. If a client is dissatisfied with a service provided by the counselor, this must be reported in writing within eight days after the session. Consultation may then take place to determine how the client’s concerns can reasonably be addressed.

Liability

a. In the event of gross negligence by the counselor, any liability applies only insofar as it is acknowledged and covered by the counselor’s insurance, up to the amount paid out by the insurer, and otherwise up to the amount involved in the assignment for that client. If the counselor causes damage to a client’s buildings or property or causes personal injury, liability applies only insofar as it is acknowledged and covered by insurance, up to the amount paid out by the insurer, and otherwise up to the amount involved in the assignment. The counselor cannot be held liable for direct or indirect consequences of normal, incorrect, or improper use of the services and information provided, nor for consequential damages. In all other cases not mentioned above, liability is limited to the amount involved in the assignment for that client.

b. All services are governed by Dutch law.

 

PRIVACY DOCUMENT Veronica Kroon

I take privacy seriously. Your information is processed and used in a secure manner. This privacy statement explains how I handle your personal data.

Personal data I process

I process your personal data because you use my services and/or because you provide this data to me. Below is an overview of the personal data I process:

The following data is recorded in the collaboration agreement:

  1. Client's name, gender, occupation, address/postcode/city, phone numbers, email address, insurance company, relationship number, GP (name and address), client’s consent for notifying the GP, physical complaints, medication use, substance use (drug/alcohol use, etc.).
    Previous treatments (psychotherapeutic, psychological, psychosocial or psychiatric), current treatments (medical, psychological, psychiatric, alternative), practitioner, diagnosis, advice, results.
  2. Brief description of the presenting issue – complaint – problem (in a maximum of 10 sentences).
  3. Motivation to resolve the complaint (on a scale of 1 to 10).
  4. Therapy will be considered successful by me as a client when: (in a maximum of 10 sentences).
  5. How will you notice that you have achieved the above?: (in a maximum of 10 sentences).
  6. Date and location of the intake, with the client’s and therapist’s signatures. These details are filled in digitally by the client and signed. If sent encrypted, I will add it to the digital treatment file. If the client chooses to give it to me in printed form, I scan it, and the paper document is shredded. The digital treatment file contains a general record of the session content and methods used, to monitor the progress of the treatment.

Purpose and legal basis for processing personal data

In addition to the GDPR, the WGBO (Medical Treatment Contracts Act) and the codes of conduct of my professional association and the Register of Complementary Healthcare Professionals (RBCZ) apply to my work. These influence the purposes for which I record personal data.

For this reason, I handle personal data as follows:

  • Record-keeping obligation: Under the WGBO, I am required as a healthcare provider to maintain a medical file.
  • Retention period: The general rule for storing medical records under the WGBO is 20 years, calculated from the date each individual entry is recorded. This period may be extended if necessary for treatment (e.g., in the case of a chronic illness).
  • Confidentiality: As a therapist, I am bound by a professional code and the legally regulated medical professional confidentiality. Employees of a psychosocial or complementary practice are bound by a confidentiality agreement in their employment contract.

Automated decision-making

I do not make decisions based on automated processing that could have significant consequences for individuals. This refers to decisions made by computer programs or systems, without any human intervention by me.

Who has access to client records?

  1. I am a self-employed professional and the only person with access to client records. I am bound by a professional code of confidentiality. No one else has access to personal data.
  2. In peer review groups with colleagues, we discuss anonymised and unrecognisable case studies. This is always done in the best interest of the client's treatment.
  3. Appointments are made in an electronic calendar, which only I can access through my phone and laptop, both of which are password-protected.

How I protect personal data

I take the protection of your data seriously and take appropriate measures to prevent misuse, loss, unauthorised access, unwanted disclosure, and unauthorised modification. If you feel your data is not properly secured or suspect misuse, please contact me.

Technical security measures

  • Up-to-date antivirus software
  • Unique login codes and passwords for systems
  • Secure backups
  • Firewalls

Organisational security measures

  • Do not leave laptops/computers unattended or in the car
  • Clean desk policy
  • Careful use of USB sticks
  • Proper disposal of old documents

External individuals or companies with access to personal data

  1. I handle invoicing myself. My accountant processes my financial administration.
  2. I process client data in Word, not in an electronic environment, so no third parties are involved.
  3. Weekly backups of my data are made to a secure Dropbox vault.
  4. Since I send invoices by email (with the client’s permission), Outlook/Microsoft is jointly responsible for securely managing email traffic. You can read the Microsoft privacy statement here: https://privacy.microsoft.com/nl-nl/privacystatement

Sharing personal data with third parties

I only share your data with third parties if necessary for the execution of our agreement or to comply with a legal obligation.

Access, modify, or delete personal data

You have the right to access, correct, or delete your personal data. You also have the right to withdraw your consent for data processing or object to the processing of your personal data by me and have the right to data portability. Let me know if you wish to exercise these rights.

Handling data breaches

Since 1 January 2016, the data breach notification obligation applies. This means that organisations (including therapists) must immediately (within 72 hours of the breach) report a serious data breach to the Dutch Data Protection Authority. Sometimes, the breach must also be reported to the individuals involved (the people whose data was leaked).

When do I need to report a data breach? I only need to report a data breach to the Dutch Data Protection Authority if it leads to serious adverse consequences for the protection of personal data or if there is a significant chance that this will happen. This is the case if, due to the breach, either personal data has been lost (and you cannot recover it, and there was no backup), or unlawful processing of personal data cannot be excluded (someone may have had access to the data who was not authorised, and you do not have control over what they did or will do with the data). I only need to inform the affected individuals (the clients whose data I process) if a breach is likely to have adverse effects on their personal privacy. This could occur if sensitive data (e.g., health information) was leaked and could be misused by third parties.

  1. I understand when I need to report a data breach and will act accordingly. The only possible breach would be if my laptop were stolen, which I monitor closely.
  2. I have agreements in place with suppliers in the processor agreement, and I am notified in a timely manner if a data breach has occurred. In my case, this would only involve the hacking of my email.

Changes

This privacy statement may be modified. These changes will be announced via the website.

Questions

If you have any questions about this privacy statement, please contact me.

Veronica Kroon, BalansKompass

Disclaimer

Section 1

The terms of this disclaimer apply to this website: BalansKompass (www.balanskompass.nl). By visiting this website, you agree to the applicability of this disclaimer.

Article 1

The information on this website is intended solely as general information. No rights can be derived from the information on this website. Although BalansKompass exercises due care in compiling and maintaining this website, it cannot guarantee the accuracy, completeness, or timeliness of the information provided. BalansKompass also does not guarantee that the website will function without errors or interruptions.

BalansKompass is not liable for any damage resulting from inaccuracies or omissions in the information provided, nor for damage resulting from problems caused by, or inherent in, the dissemination of information via the internet, such as malfunctions, interruptions, errors, or delays in the provision of information by us or by you to us through our website or otherwise by electronic means.

Article 2

BalansKompass retains all intellectual property rights and other rights with regard to all information offered on or via this website (including all texts, graphic materials, and logos). It is not permitted to copy, download, publish, distribute, or reproduce information from this website in any manner without prior written consent from BalansKompass.

You may print and/or download information from this website for your own personal use. Unauthorized or improper use of the content or any part thereof constitutes an infringement of intellectual property rights.

Article 3

BalansKompass reserves the right to amend the information offered on or via this website, including the text of this disclaimer, at any time without prior notice. It is advisable to periodically check whether the information provided on or via this website, including the text of this disclaimer, has been modified.

Section 2

This website and this disclaimer are governed by Dutch law. All disputes arising out of or in connection with this disclaimer shall be submitted exclusively to the competent court in the Netherlands.