Data Privacy Policy
ADZ FeRaL Psychosocial Services • Republic of the Philippines
1. Declaration of Privacy & Clinical Commitment
ADZ FeRaL Psychosocial Services ("ADZ FeRaL", "we", "us", or "our") operates as a specialized mental health clinic and psychosocial practice management platform based in the Republic of the Philippines. We recognize that mental health records, clinical intake notes, and psychometric evaluation data constitute the most sensitive category of personal information.
We are unreservedly committed to safeguarding your fundamental right to privacy pursuant to the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, NPC Advisory Opinions, and the statutory confidentiality mandates established under the Mental Health Act (Republic Act No. 11036).
2. Personal Information Controller (PIC) & Data Protection Officer
Under RA 10173, ADZ FeRaL acts as the Personal Information Controller (PIC) with respect to client personal profiles, appointment scheduling data, and account authentication credentials.
3. Categories of Information We Collect & Process
To provide safe, ethical, and clinically accurate psychosocial care and assessment tools, we collect the following categories of data:
A. General Personal Information
- Full Legal Name, Email Address, and Mobile Number (Philippine format).
- Date of Birth, Age, Biological Sex, and Gender Identity.
- Emergency Contact Information (Name, Relationship, Contact Number).
- Account Credentials (Password hashes, TOTP Two-Factor Authenticator secrets).
B. Sensitive Mental Health Records
- Consultation history, appointment notes, and treatment progress summaries.
- Cognitive IQ and Behavioral & Personality Inventory (BPI) test responses.
- Scanned OMR answer sheets and handwriting analysis image uploads.
- Psychologist clinical observations and graded psychometric evaluation reports.
4. Lawful Basis and Purpose of Processing
We process your personal and sensitive data strictly under the following lawful bases permitted under Section 12 and Section 13 of RA 10173:
- Explicit Informed Consent: You voluntarily provide written or digital consent upon registering and booking psychological consultations or tests.
- Contractual Performance: Processing necessary to confirm appointments, manage schedules, and deliver psychological evaluation results.
- Medical & Psychosocial Necessity: Pursuant to Section 13(e) of RA 10173 and RA 11036, processing is carried out by or under the responsibility of licensed healthcare and psychological professionals subject to professional confidentiality.
- Protection of Vital Life Interests: Where processing is necessary to protect your life or the life of another individual in an acute medical emergency.
5. Rigorous Security Safeguards & Architecture
ADZ FeRaL employs institutional-grade technical, physical, and organizational security measures to protect mental health records from accidental destruction, unlawful alteration, unauthorized disclosure, or data exfiltration:
6. Third-Party Service Sub-Processors
We never sell, rent, or monetize your clinical information. We engage only reputable, vetted infrastructure partners strictly bound by confidentiality:
- Semaphore SMS Gateway: Dispatches purely transactional reminder texts (e.g. "Your appointment is confirmed for Oct 15 at 10:00 AM"). Strict Policy: Zero diagnostic details, mental health symptoms, or clinical notes are ever transmitted across SMS networks.
- Microsoft Azure Cognitive Services: Secure optical recognition for digitizing physical OMR answer sheets under enterprise HIPAA and ISO 27001 compliant cloud privacy boundaries.
- Direct Clinical Billing: All consultation and assessment fees are handled directly in-clinic. ADZ FeRaL does not integrate or store data through online payment gateways on this website.
7. Retention and Safe Disposal of Records
Pursuant to professional standards prescribed by the Professional Regulatory Board of Psychology (PRC) and clinical documentation guidelines:
- Psychological assessment records, consultation notes, and graded OMR score profiles are securely retained for a minimum period of five (5) to seven (7) years following the final date of active consultation.
- For minor clients, clinical records are retained until five (5) years after the client attains the age of majority (18 years).
- Upon expiration of the retention threshold, physical sheets are incinerated or cross-cut shredded, and digital files are permanently erased using DoD-compliant digital sanitization methods.
8. Your Statutory Rights as a Data Subject
Under the Philippine Data Privacy Act of 2012, you possess the following inviolable rights:
9. How to Exercise Your Privacy Rights
To submit a subject access request, update your information, or inquire about clinical confidentiality, please contact our Data Protection Officer: