London Communication Clinic: Data Privacy Notice
About London Communication Clinic:
London Communication clinic is a specialist independent speech and language therapy provider www.londoncommunicationclinic.com. The clinic has been set up by Jennifer Warwick, a specialist speech and language therapist working with children and young people either in clinic, homes or education settings.
I am registered with the Health Care Professions Council (registration number SLT2025) and a member of the Royal College of Speech and Language Therapists (RCSLT) and Association of Speech and Language Therapists in Private Practice. Medical Malpractice and Public Liability Insurance is provided by Nova Underwriting Limited in Line with membership of the RCSLT.
Jennifer Warwick is registered with the Information Commissioner’s Office (reference: ZA446328) as a Data Controller and as a sole trader she also acts as the Data Processor.
Personal data collected:
Why do we gather personal data?
Personal data is gathered in order to provide a high quality speech and language therapy service that complies with HCPC (health care professions council) Standards of Conduct Performance and Ethics.
London Communication Clinic gathers 2 types of data:
1. Personal Details - this includes, names, addresses, contact details, date of birth, child’s education setting, GP of:
- Children and young people who are referred and seen for assessment and therapy
- Their legal guardians
- Commissioners of SLT services e.g. (schools)
- Students who carry out university placements
- Other professionals I work with
Personal details are collected through spoken and written communication with a child or young person’s legal guardian or educational setting. This may be face-to-face, telephone calls, emails, referral forms and enquires via the website.
Only information that is relevant or required to provide speech and language therapy services will be collected.
2. Health care records - this includes
- Developmental, medical, family and educational history
- Assessment findings and observations
- SLT intervention goals, progress and outcomes
- SLT session notes
- Written reports and feedback documents
- Report from other professionals (where appropriate)
Developmental, medical, family and educational history information is gained from written and verbal communication with legal guardians, educational or other professionals. All other data is gathered through direct interaction with the child through observation, formal and information assessment and therapy intervention.
How do we store your data?
- Data is stored within the clients record within secure and encrypted cloud storage provided by Cliniko.
- Paper copies of online data may also stored during period of intervention
- These are stored in a locked filing cabinet at the address registered with the ICO.
- Data provided by parents/other professionals via email (not including attachments which will be uploaded and deleted from email) may also remain on email in secure inbox provided by gmail.com until time of discharge.
- Data provided by legal guardians/ schools/ other professionals is sent via secure email. This is stored within the client’s electronic record.
- Addresses required for home visits are stored in the therapist’s online diary. This is anonymised in order to maintain confidentiality.
Do you share my data?
Client confidentiality is of utmost importance and will be maintained at all times by keeping your data secure. Data will, however, where relevant be shared confidentially and appropriately with other professionals involved with the client in line with my duty of care to share information with other health and social care providers as set out in the Heath and Social Care Act (2012). Signed consent will be sought from you around sharing information. You will always be informed of information sharing unless in the case of safeguarding. I am duty bound to share any concerns regarding safeguarding (i.e. a risk or incidence of abuse or neglect) of any child or vulnerable adult with the relevant agencies.
How long will the data be stored?
- Health Care Documents are Special Category data and as such are exempt from the ‘right for erasure’: Under ‘The Limitation Act’ (1980) a child who has received SLT as a child has 6 years from the age of 18 to bring legal action if they feel any misconduct has taken place. Best practice guidelines therefore state (Information Governance, 2016) that client records should be retained until the child reaches the age of 25.
- At this time the online record will be fully deleted. Any paper documents, however, will be shredded at time of discharge.
- Media Files and Emails that are not a key part of a child’s health care record will be deleted as soon as possible and at the latest when discharged from London Communication Clinic.
- Email information that are relevant to the child’s health care record will be uploaded to join the child’s online file.
- Personal details form part of a child’s health care record and will be stored with this as outlined above.
How do you keep my data safe?
- All data will be stored in secure and encrypted online cloud storage and not on individual devices.
- Use of up-to-date antivirus software
- Using secure file sharing facilities where possible and encrypted/password protected documents when sharing data
- via email and only shared with trusted email addresses.
- Keeping up to date with information from the ICO and other relevant organisations and reviewing/updating policies.
- Storing any paper documents in a locked cabinet (with the key in a hidden location), when not in use and not left unaccompanied during transportation.
- Anonymising data where ever possible e.g. in diaries, handwritten notes taken in sessions.
What are my rights?
- You have the right to withdraw your consent for Speech and language Therapy intervention at any time and no further data will be collected.
- You have the right to change your preferred methods of communication.
- You have the right to update any incorrect information and it is important that you inform me of any changes to your personal details so that I can keep your data accurate.
- You have the right to request a copy of the personal information that is held about you and your child. This is called a Subject Access Request and it is free of charge. All requests will be processed and completed within 30 days of receipt.
- Health care documents, as special category data are exempt from the right for erasure and will be maintained in line with the procedures set out in this policy.
Will you use my data for any other purposes?
- Your child’s personal data will never be used for marketing purposes or any other purposes other than those set out above.
- Your child’s personal data will never be sold to or shared with any third parties for marketing or any other purposes.
How can I make a complaint?
If you have a query or complaint please contact Jennifer Warwick on the details below in the first instance to discuss your concerns.
If I am unable to resolve your complaint or you wish to instigate a formal complaint you can contact:
- The Information Commissioner’s Office if your complaint is regarding Data Processing ico.org.uk/make-a-complaint
- ASLTIP (www.helpwithtalking.com) or HCPC (www.hcpc-uk.org) if your complaint is regarding the Speech and Language Therapy services you have received.