Who am I?
I operate as a sole trader, delivering independent speech and language therapy to children in the home and/or educational setting. I am registered with the Health Care and Professional Council (HCPC). I am committed to protecting the privacy of information provide by clients.
Collection of personal information
Information about your child may be collected via spoken or written information from parents/carers. With parental consent, information may also be collected from other professionals working with your child (such as teachers, nursery staff, child minders, NHS Speech and Language Therapists and Educational Psychologists). I may also collect information about family members where this relates to your child e.g. contact details for parents and relevant medical or developmental history.
Use of Personal Information
Personal information collected email, telephone or face to face is stored and used for the purpose of delivering your child’s speech and language therapy.
Any sensitive personal details are stored in a secure and confidential system and processed in confidence and shall only be used for the purposes of delivering appropriate speech and language therapy services to your child.
With your consent, information about your child’s speech and language needs will be shared with other professionals involved in your child’s care, when it is in your child’s best interests. A record of your consent is kept with your child’s case notes. Unless I am required to do so by law, I will not disclose any personal information collected to any person other than as set out above.
I do not employ agents to process personal data, for example specialist mailing companies to send out communications. I do not give or sell client details to any third parties.
How I use personal information
I will use this information:
- To prepare, plan and provide speech and language therapy services appropriate for your child’s needs.
- To communicate with you via post, email, telephone, mobile messages and SMS in relation to: – confirming and preparing for appointments – general communication in between appointments – sending you reports and programmes for your child (always password protected) – copying you in to communications with other professionals involved with your child (your child’s initials rather than full name will be used in emails) – sending you resources – sending you invoices and receipts.
- For clinical audit to assess and improve my service. Results of audits are always presented with all client identities removed.
- For management and administration and accounting purposes.
How I store personal information
All information about you, your child and their speech and language therapy is stored securely in my systems to ensure that I have a complete record of our service to them. I use a secure electronic cloud-based system which is compliant with general data protection regulations and is only accessible via a password held by Sharon Worsley. My computer hardware is all encrypted. Any paper based confidential information such as assessments are stored securely in accordance with Data Protection Regulations. The minimum amount of confidential information will be taken out of my office base. When your child’s information is taken out of the office base it will be kept with the me or will be locked in the boot of my car (whichever is deemed to be the most secure at that time). In accordance with HCPC guidelines, all records will be kept securely until your child is 25 years old. After this time all records relating to your child will be destroyed. I take all measures reasonably necessary to prevent unauthorized access, use, alteration or destruction of potentially personally-identifying and personally identifying information.
Meeting my professional obligations
I process and store personal information to comply with my legal obligations.It is a legal requirement for all Speech and Language Therapists to be registered with the Health and Care Professions Council (HCPC). The HCPC has clear standards of conduct, performance and ethics that all registrants must adhere to. These standards affect the way in which I process and share information. Specifically:
Standard 2: Communicate appropriately and effectively
“You must share relevant information, where appropriate, with colleagues involved in the care, treatment or other services provided to a service user.”
Standard 10: Keep records of your work
“You must keep full, clear, and accurate records for everyone you care for, treat, or provide other services to. You must complete all records promptly and as soon as possible after providing care, treatment or other services. You must keep records secure by protecting them from loss, damage or inappropriate access.”
For further information the full document can be found at: http://www.hcpcuk.org/assets/documents/10004EDFStandardsofconduct,performanceandethics.pdf
My Lawful basis for processing information
My lawful basis for processing and storing personal information is one of ‘legitimate interest’ (under article 6 of GDPR). I cannot adequately deliver a service to your child without processing their personal information. As it is both a necessity for my service delivery and of benefit to your child, we have a legitimate interest to process and store their data.
Data relating to an individual’s health is classified as ‘Special Category Data’ under section 9 of the GDPR. The regulations specify that health professionals who are “legally bound to professional secrecy” may have a lawful basis for processing this data. Speech and Language Therapists are legally bound to keep client information confidential and it is under this condition that we process and store personal information
The Data Protection Act 1988 and General Data Protection Regulations 2018
The Data Protection Act 1988 and The General Data Protection Regulations 2018 lay down wide ranging rules, backed up by criminal sanctions, for the processing of information about identifiable, living individuals. It also gives individuals certain rights in relation to personal data held about them by others.
I am registered with the Information Commissioner’s Office (ICO) as a Data Controller. You can view my ICO registration by visiting: www.ico.org.uk/ESDWebPages/Entry/ZA051488
I am committed to maintaining the security and confidentiality of your child’s record. I actively implement security measures to ensure their information is safe, and audit these regularly. I will not release your personal details to any third party without first seeking your consent, unless this is allowed for or required by law. I am constantly working to ensure compliance with current data protection regulation.
Data protection legislation gives you, the parent, various rights. The most important of these are as follows:
- You have the right to a copy of information I hold about your child.
- You have the right to ask for your record to be amended if you believe that it is wrong.
How to access your child’s records
You can access the information I hold about you by writing to me at the address given below. A copy of your child’s records is provided free of charge. I will provide access to your child’s records within 30 days of receipt of all necessary information.
Please make your request in writing to:
Subject Access Requests. SWSLT, 22 Norman Road, Barton Le Clay, Beds, MK45 4QP. If you have any further questions about how I use your information, please contact firstname.lastname@example.org.
Further information about data protection legislation and your rights is available from the Information Commissioner’s Office or by calling 0303 123 1113, 9am to 5pm, Monday to Friday,
Date: April 2018