Privacy Policy
Preamble and Acceptance
This Privacy Policy explains how Psycho Analytic Board Org, available at https://psychoanalyticboard.org, processes personal information associated with access to, navigation of, communication with, and use of the website.
Psycho Analytic Board Org is a digital institutional, academic-editorial, educational, ethics, training-standards, and governance project focused on psychoanalysis.
The website may publish articles, essays, reference materials, educational analyses, ethical principles, training standards, institutional policies, governance recommendations, historical materials, theoretical discussions, and other content concerning psychoanalysis, psychology, mental health, professional education, clinical ethics, scholarship, and related fields.
The term “Board” forms part of the project's institutional and editorial identity. It does not, by itself, mean that Psycho Analytic Board Org is a governmental board, state licensing authority, statutory professional council, recognised accrediting agency, disciplinary tribunal, university, degree-granting institution, or authority empowered to regulate professional practice.
Standards, policies, ethical principles, training criteria, or governance recommendations published by the website should be understood as standards adopted, proposed, analysed, or described by the project unless a legally recognised external authority is expressly identified and accurately cited.
Psycho Analytic Board Org is not a hospital, medical practice, psychology clinic, psychotherapy service, psychoanalytic treatment service, telehealth provider, or emergency mental health service.
The website does not provide psychoanalytic treatment, psychotherapy, medical or psychological diagnosis, psychological testing, clinical screening, prescriptions, individualised treatment plans, patient management, or emergency care.
By accessing or using the website, visitors acknowledge this Privacy Policy. Where consent is legally required for a specific processing activity, an appropriate consent mechanism will be used.
Applicable United States federal and state privacy requirements will be observed where their statutory conditions are satisfied, including, where applicable, the California Consumer Privacy Act as amended by the California Privacy Rights Act, the Children's Online Privacy Protection Act, federal consumer-protection law, and applicable state privacy and security requirements.
Where Regulation (EU) 2016/679, the General Data Protection Regulation, applies territorially and materially to a particular processing activity, its applicable requirements will also be observed.
Where UK GDPR, Brazil's Law No. 13,709/2018, Peru's Law No. 29733, or another foreign privacy regime has mandatory application to a specific operation, its applicable requirements will also be considered.
Data Controller and Data Protection Officer (DPO)
For transparency purposes, Psycho Analytic Board Org is the public institutional and editorial designation used for the digital project presented through https://psychoanalyticboard.org.
The use of that designation does not independently establish the existence of a corporation, government agency, professional licensing board, university, accredited educational institution, clinic, healthcare organisation, or physical institution bearing that name.
The person or organisation that actually determines the purposes and essential means of a particular personal information processing activity will be treated as the relevant controller, business, or equivalent responsible party under the law applicable to that operation.
Prof. Helena Martens is identified as an editorial contact associated with the production, curation, review, or communication of website content.
That identification does not, by itself, constitute appointment as Data Protection Officer or independently establish a regulated clinical licence, academic appointment, board certification, professional registration, government position, or accreditation authority.
The privacy contact channel is helenamarten@psychoanalyticboard.org.
United States privacy law does not generally require every informational website to appoint a Data Protection Officer. Where Article 37 of the GDPR, the UK GDPR, or another applicable regime requires formal DPO appointment for a particular processing operation, the required designation and contact information will be provided.
Legal Definitions
For purposes of this Policy, the following terms are used according to applicable law:
- Personal information or personal data: information relating to an identified or identifiable individual, as defined by applicable law.
- Sensitive personal information: information receiving heightened protection because of its nature, which may include health information, racial or ethnic origin, religious beliefs, sexual orientation, precise geolocation, biometric information, or other protected categories.
- Processing: collection, use, organisation, storage, analysis, disclosure, transmission, modification, restriction, or deletion of personal information.
- Consumer or data subject: an individual whose personal information is processed and who may receive rights under applicable law.
- Controller: a person or organisation determining the purposes and essential means of processing.
- Service provider or processor: a person or organisation processing personal information for another responsible party under applicable requirements.
- Consent: an affirmative authorisation satisfying the requirements applicable to the specific processing activity.
- Clinical data: information collected or generated for diagnosis, treatment, psychotherapy, psychoanalytic treatment, psychological assessment, patient care, or another individualised clinical purpose.
- Training standard: an educational or institutional criterion describing expectations concerning psychoanalytic study, theory, ethics, supervision, clinical formation, scholarship, or related education, without automatically constituting a statutory licensing or accreditation requirement.
- Institutional standard: an ethical, governance, academic, editorial, or professional-development criterion adopted or discussed by the project.
- Health inference: a conclusion or prediction concerning a person's physical or mental health derived from information or behaviour.
- Profiling: systematic or automated processing used to evaluate, classify, predict, or infer characteristics concerning an individual where recognised by applicable law.
- Cookies: files, identifiers, pixels, scripts, or comparable technologies used for technical functionality, security, preferences, analytics, advertising, or other disclosed purposes.
Information We Collect
Information Voluntarily Provided
When visitors contact the website, submit a question, suggest a correction, provide feedback on an ethical or educational standard, propose editorial material, or use another available communication function, the website may process information such as name, email address, voluntarily supplied institutional affiliation, subject, and message content.
NO CLINICAL DATA IS REQUESTED OR INTENTIONALLY COLLECTED THROUGH THE WEBSITE'S ORDINARY FUNCTIONALITY FOR DIAGNOSIS, PSYCHOANALYTIC TREATMENT, PSYCHOTHERAPY, CLINICAL SCREENING, OR PATIENT CARE.
Visitors must not submit medical records, psychotherapy notes, psychoanalytic session transcripts, psychological assessments, diagnoses, prescriptions, patient histories, or other confidential clinical records through ordinary editorial or institutional contact channels.
Technical and Navigation Information
Technical information may be processed during access, including Internet Protocol address, date and time, browser, operating system, device type, requested pages, approximate referral source, technical identifiers, and security events.
Audience and Performance Information
Where analytics technologies are actually implemented, information concerning page views, approximate session duration, referral sources, interactions, clicks, and technical performance may be processed.
Academic, Ethical, and Institutional Communications
Communications concerning training standards, ethics, governance, publications, research, historical psychoanalysis, institutional questions, professional education, or scholarly collaboration may contain professional contact information and other information voluntarily supplied by the sender.
Such information should be used only for purposes reasonably compatible with the relevant communication.
Feedback on Training Standards
If the website requests comments concerning proposed educational, ethical, supervisory, or governance standards, information may be processed to evaluate feedback, document review, communicate with contributors, and improve the relevant material.
Providing feedback does not automatically establish membership, faculty status, professional certification, accreditation, employment, voting rights, or regulatory authority.
Psycho Analytic Board Org does not maintain patient charts or clinical records as part of its intended website functionality.
Legal Bases for Processing
In the United States, privacy requirements vary according to the nature of the information, the responsible party, the user's jurisdiction, the purpose of processing, and the statutory scope of applicable federal and state law.
Where the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to the responsible business, personal information will be handled consistently with California Civil Code section 1798.100 and following provisions and applicable California regulations.
Where the Children's Online Privacy Protection Act applies, covered online collection involving children under 13 will be handled according to 15 U.S.C. sections 6501 through 6506 and 16 CFR Part 312.
Where the Federal Trade Commission Act applies to representations concerning privacy, security, institutional status, professional standards, certification, training, or services, representations should not be unfair or deceptive.
Where processing is subject to the GDPR, an appropriate lawful basis under Article 6 will be identified.
Where GDPR-covered processing involves health information or another special category of personal data, an appropriate condition under Article 9 must also be identified.
Depending on the specific GDPR-covered activity, relevant bases may include consent, contractual necessity, compliance with a legal obligation, protection of vital interests, or legitimate interests where legally permissible and appropriately balanced.
Where UK GDPR applies, corresponding lawful bases and safeguards will be observed.
Where Brazil's Law No. 13,709/2018 applies, an appropriate legal basis under Articles 7 or 11 will be identified.
Where Peru's Law No. 29733 applies, the corresponding privacy, transparency, security, proportionality, and data-subject requirements will be observed.
Worldwide accessibility of the website does not automatically make every foreign privacy regime applicable to every processing operation.
Purposes of Processing
Personal information may be processed, where appropriate, to:
- operate and secure the website;
- deliver educational, ethical, and institutional materials;
- respond to correspondence and enquiries;
- review corrections and scholarly suggestions;
- receive feedback on proposed training or governance standards;
- manage editorial submissions where offered;
- manage comments where enabled;
- record privacy and cookie preferences;
- prevent fraud, spam, attacks, malicious automation, and unauthorised access;
- identify technical failures;
- produce website-performance and audience statistics where legally appropriate;
- understand aggregate interest in psychoanalytic topics;
- improve accessibility and editorial organisation;
- maintain citation, source, authorship, policy-version, and correction records;
- document development of institutional standards;
- comply with applicable legal obligations;
- respond to valid governmental, judicial, or regulatory requests;
- establish, exercise, or defend legal rights;
- investigate security incidents.
Reading content concerning trauma, psychosis, neurosis, narcissism, sexuality, depression, anxiety, suicide, transference, personality, or another psychoanalytic or mental-health subject will not, by itself, cause the website to determine that the visitor has that condition or psychological structure.
Sensitive Data and Mental Health
PSYCHO ANALYTIC BOARD ORG DOES NOT REQUEST OR INTENTIONALLY COLLECT CLINICAL DATA THROUGH ITS ORDINARY WEBSITE FUNCTIONALITY FOR DIAGNOSIS, PSYCHOANALYTIC TREATMENT, PSYCHOTHERAPY, CLINICAL SCREENING, PRESCRIPTION, TRIAGE, OR PATIENT CARE.
The website may publish educational material concerning trauma, sexuality, psychosis, neurosis, depression, anxiety, self-harm, suicide, personality, addiction, family relationships, dreams, and other potentially sensitive subjects.
READING AN ARTICLE OR TRAINING STANDARD ABOUT A MENTAL HEALTH OR PSYCHOANALYTIC CONCEPT DOES NOT CAUSE THE WEBSITE TO DIAGNOSE THE READER.
The website will not use reading history alone to classify a visitor as psychotic, neurotic, narcissistic, depressed, anxious, traumatised, suicidal, addicted, or as having another mental-health condition or psychoanalytic structure.
ACADEMIC OR PROFESSIONAL INTEREST IN PSYCHOPATHOLOGY OR PSYCHOANALYTIC THEORY IS NOT, BY ITSELF, CLINICAL EVIDENCE ABOUT THE READER.
Where California privacy law applies, qualifying health information may fall within categories of sensitive personal information protected by that law.
Where the GDPR applies, health information may constitute special category personal data under Article 9.
The website is not designed as a patient-record system, psychological-testing service, or clinical assessment platform.
Visitors should not submit identifiable patient information, session transcripts, medical records, psychotherapy notes, diagnoses, prescriptions, or confidential clinical files through ordinary website channels.
If such information is nevertheless sent without solicitation, its receipt will be incidental and will not create a treatment relationship or patient record.
Incidental sensitive information should be minimised, restricted, or deleted where reasonably appropriate and legally permissible.
INCIDENTALLY RECEIVED CLINICAL INFORMATION WILL NOT BE REPURPOSED BY THE WEBSITE FOR BEHAVIOURAL ADVERTISING, READER DIAGNOSIS, OR UNRELATED CLINICAL PROFILING.
Cookies and Tracking Technologies
The website may use cookies and comparable technologies for technical functionality, cybersecurity, privacy preferences, analytics, and other disclosed purposes.
- Strictly necessary technologies: technologies required to operate or secure essential website functions.
- Functional technologies: technologies used to remember requested settings or preferences.
- Analytics technologies: technologies used to understand aggregate audience behaviour and website performance.
- Advertising or cross-context behavioural technologies: technologies used for advertising or related tracking only where actually implemented and subject to applicable legal requirements.
Optional technologies should not be described as strictly necessary when they are not essential to the requested service.
Where consent is legally required, optional technologies will be subject to an appropriate consent mechanism.
Where the CCPA applies and a processing practice constitutes sale or sharing of personal information under California law, legally required opt-out mechanisms will be made available.
Where legally required, applicable opt-out preference signals, including Global Privacy Control signals, will be honoured.
The website should not create sensitive advertising audiences solely because a visitor reads articles concerning psychosis, trauma, sexuality, depression, suicide, addiction, or another mental-health topic.
Sharing with Third Parties
Psycho Analytic Board Org does not have, as its stated institutional purpose, the commercial sale of readers' personal information.
Personal information may be disclosed on a limited basis to providers necessary for website operation, including hosting, cybersecurity, email, forms, content delivery, backups, analytics, and technical infrastructure.
Each provider may act as a service provider, processor, contractor, independent business, or controller depending on the applicable legal framework and actual arrangement.
Only information reasonably necessary for the relevant purpose should be disclosed.
Related Educational and Institutional Projects
The website may reference or link to psychoanalytic institutes, schools, academic projects, publishers, professional organisations, journals, universities, or related editorial websites.
A LINK, SIMILAR NAME, SHARED SUBJECT AREA, EDITORIAL RELATIONSHIP, OR RELATED DESIGN DOES NOT AUTOMATICALLY ESTABLISH COMMON LEGAL OWNERSHIP, ACCREDITATION, PROFESSIONAL RECOGNITION, OR PERMISSION TO SHARE PERSONAL INFORMATION.
Cross-domain data sharing should occur only where there is an appropriate purpose, transparency mechanism, security arrangement, and legal basis.
Information may also be disclosed where required by valid law, judicial process, regulatory demand, or the establishment, exercise, or defence of legal rights.
International Data Transfers
Because the website is internationally accessible, technology providers may process personal information in the United States or other countries.
Where the GDPR applies to a transfer outside the European Economic Area, an appropriate transfer mechanism under Articles 44 through 49 will be considered, including an adequacy decision, Standard Contractual Clauses, or another legally available mechanism.
Where UK GDPR applies, corresponding international-transfer safeguards will be considered independently.
Where Brazilian LGPD applies to a particular transfer, Articles 33 through 36 and applicable Brazilian regulations will be observed.
Where Peru's Law No. 29733 applies, relevant transfer and security requirements will be considered.
International processing does not eliminate obligations concerning reasonable security, transparency, purpose limitation, and data minimisation.
Retention and Deletion
Personal information will be retained only for as long as reasonably necessary for the purpose for which it was processed, subject to applicable legal, security, editorial, institutional, evidentiary, and rights-protection requirements.
General correspondence may be retained for a reasonable period necessary to respond, document institutional communications, prevent abuse, or protect legal rights.
Records relating to authorship, standards development, policy versions, editorial corrections, copyright permissions, source verification, or publication history may be retained where reasonably necessary.
Sensitive information unnecessarily included in ordinary correspondence should be minimised or deleted where technically and legally appropriate.
Where COPPA applies, personal information from children will not be retained longer than reasonably necessary for the purpose for which it was collected, subject to applicable requirements.
Where California law applies, deletion requests will be addressed subject to statutory exceptions.
Where GDPR applies, the storage-limitation principle under Article 5 will be observed.
Rights of Individuals
California Privacy Rights
Where the CCPA applies, eligible California consumers may have rights including:
- the right to know categories and specific pieces of personal information, subject to applicable requirements;
- the right to request deletion, subject to statutory exceptions;
- the right to request correction of inaccurate personal information;
- the right to opt out of sale or sharing where applicable;
- the right to limit certain uses and disclosures of sensitive personal information where statutory requirements are satisfied;
- the right to receive required information concerning purposes, categories of sources, and categories of recipients;
- the right not to receive unlawful discriminatory treatment for exercising applicable privacy rights.
Automated Processing
Where applicable California regulations concerning automated decisionmaking technology apply to a covered business and activity, corresponding notice, access, opt-out, risk-assessment, or other requirements will be addressed according to their legal scope.
Psycho Analytic Board Org is not intended to make automated clinical diagnoses, professional licensing determinations, disciplinary decisions, accreditation decisions, or legally significant eligibility decisions about ordinary website visitors.
European Rights
Where the GDPR applies, individuals may have rights under Articles 12 through 22, including access, rectification, erasure, restriction, portability, objection, withdrawal of consent, and safeguards relating to certain automated decisions.
Where UK GDPR applies, corresponding rights will be respected.
Other Applicable Rights
Where Brazilian LGPD applies, rights under Article 18 will be observed.
Where Peru's Law No. 29733 applies, corresponding legally applicable rights will be respected.
How to Exercise Your Rights
Privacy requests may be submitted to helenamarten@psychoanalyticboard.org.
Reasonable verification may be required to prevent unauthorised access, alteration, disclosure, or deletion of personal information.
The website should not request excessive information where a less intrusive verification method is reasonably sufficient.
Requests will be evaluated according to the jurisdiction, statutory scope, nature of the request, and information actually processed.
Where applicable law permits an authorised agent to act for an individual, reasonable evidence of that authority may be requested.
If a request cannot be granted in whole or in part, the reason may be provided where required or appropriate under applicable law.
Information Security
The website seeks to maintain reasonable technical and organisational safeguards appropriate to the nature and risk of the personal information processed.
Measures may include HTTPS, software updates, authentication controls, restricted administrative access, least-privilege practices, backups, malicious-traffic protection, technical logging, and provider review.
IDENTIFIABLE PATIENT RECORDS, SESSION TRANSCRIPTS, PSYCHOTHERAPY NOTES, PSYCHOLOGICAL ASSESSMENTS, OR CONFIDENTIAL CLINICAL FILES MUST NOT BE USED AS ORDINARY EDITORIAL, DEVELOPMENT, DEMONSTRATION, ANALYTICS, OR ARTIFICIAL-INTELLIGENCE TEST DATA.
No Internet-connected environment can be guaranteed completely secure.
Security is therefore treated as an ongoing process involving prevention, detection, response, recovery, and improvement.
Where applicable California cybersecurity-audit, risk-assessment, or other regulatory requirements apply to a covered business and activity, corresponding compliance measures should be implemented according to their scope and effective schedule.
Where a security breach triggers notification requirements under applicable federal or state law, affected individuals and competent authorities will be notified according to the relevant requirements.
Children and Minors
The website is intended primarily for adult students, academics, professionals, researchers, educators, and other readers interested in psychoanalysis and ethics. It is not designed primarily as a service directed to children under 13.
Under the Children's Online Privacy Protection Act and 16 CFR Part 312, specific requirements apply to covered websites and online services directed to children under 13 and to certain operators with actual knowledge that they are collecting personal information online from a child under 13.
The website does not intentionally solicit personal information from children under 13 through ordinary editorial or institutional functionality.
Where verifiable parental consent is legally required, a child's unsupported representation will not substitute for the required parental-consent procedure.
If the website learns that information has been collected from a child under 13 under circumstances requiring action under COPPA, appropriate steps will be taken according to applicable law.
Children and adolescents should not be encouraged to publicly disclose diagnoses, self-harm, suicidal thoughts, sexual information, abuse, medication, psychotherapy history, family conflict, or other sensitive information through ordinary forms or comments.
Where GDPR or UK GDPR rules concerning children apply to a particular service, applicable age, transparency, consent, and child-protection requirements will also be considered.
Changes to this Policy
This Policy may be revised in response to changes in law, regulation, technology, institutional activity, or website functionality.
The Policy should be reassessed before implementing memberships, professional directories, credential verification, certification, formal training enrolment, supervision records, student accounts, behavioural advertising, AI assistants, clinical questionnaires, patient information, disciplinary complaints, or other functionality that materially changes personal information processing.
IF THE WEBSITE BEGINS COLLECTING CLINICAL RECORDS, ISSUING PROFESSIONAL CREDENTIALS, VERIFYING LICENSURE, CONDUCTING FORMAL SUPERVISION, PROCESSING PROFESSIONAL DISCIPLINARY COMPLAINTS, OR PROVIDING CLINICAL SERVICES, A SEPARATE LEGAL AND PRIVACY REVIEW MUST OCCUR BEFORE LAUNCH.
The current version will be made available through the website.
Supervisory and Enforcement Authorities
In the United States, privacy and consumer-protection matters may fall within the jurisdiction of the Federal Trade Commission, state Attorneys General, the California Privacy Protection Agency where applicable, and other competent authorities according to subject matter and statutory scope.
Where the CCPA applies, California authorities may have jurisdiction over applicable privacy matters.
Where the GDPR applies, individuals may have the right to lodge a complaint with a competent European supervisory authority.
Where UK GDPR applies, the competent United Kingdom data-protection authority may have jurisdiction.
Where Brazilian LGPD applies, the Brazilian National Data Protection Authority may have jurisdiction.
Where Peruvian data-protection law applies, the competent Peruvian personal-data protection authority may have jurisdiction.
Contact
Questions concerning this Privacy Policy or privacy rights may be submitted to:
Psycho Analytic Board Org
Website: https://psychoanalyticboard.org
Editorial contact: Prof. Helena Martens.
Email: helenamarten@psychoanalyticboard.org
Nature of the website: digital institutional and educational project focused on ethics, psychoanalytic training standards, scholarship, and governance.
Primary jurisdiction: USA.
Last Updated
Original effective date: February 11, 2020.
Legal consolidation of this version: September 8, 2026.