2.4. File management

Information is kept only for the time required for the purpose of the psychodiagnostic assessment or to the extent that legal rules apply. The Dutch Medical Treatment Contracts Act (Dutch initials: WGBO) requires as a general matter that a file be kept for 15 years, after which it must be destroyed. The Act lists exceptions for the preservation of the data for a longer period, for example in the context of the continuity of care. Not all files within the meaning of the Code fall under the WGBO. The medical treatment of a patient must be involved. In that case, the files held by a treating psychologist are also covered by the legal retention period of the WGBO. Reporting on the basis of an assessment that is carried out by a work and organisational psychologist in the context of personnel selection is not covered by this legal retention period, however. In such a case, the psychologist should choose a retention period for the file, depending on what is common in the field, having regard to the following.

The personal file within the meaning of the Code is kept for at least the period of validity of the psychological report, with a minimum term of one year (see Article 36, “Period of retention of Files”). This minimum term is chosen with a view to the possibility that the psychologist still has the file at the moment in which the client asks to inspect it, or when a complaint would be filed. Incidentally, the psychologist does not destroy the file, even after the expiry of the retention period, if a complaint has been lodged and the case has not yet been closed.

There is no fixed period in the Code for the retention of anonymised data to benefit research. The key point here is that it is no longer a matter of data that can be traced back to the client (see Article 86, “Data for publications, education, quality care, supervision, and peer review”). The psychologist makes the test data that has been collected accessible in such a way that statistical or psychometric analyses can be performed on it. To that end, the data is saved in an anonymised file. This condition is also met if the data is stored in such a way that it is easy to separate from the rest of the file data.