Privacy & Data Protection Policy
Tunbridge Wells Independent Speech and Language Therapy (TWIST) / Lida Willingale
Updated April 2021
This document confirms Tunbridge Wells Independent Speech and Language Therapy’s (TWIST)/ Lida Willingale’s commitment to protect your privacy and to process your personal information in accordance with the Data Protection Act.
Who am I?
My name is Lida Willingale, Independent Speech and Language Therapist. I am a UK Practicing Speech and Language Therapist (SLT) registered with the Health and Care Professions Council (HCPC), the Royal College of Speech and Language Therapists (RCSLT) and the Association of Speech and Language Therapists in Independent Practice (ASLTIP). I practice under my own name as well as under the brand name of Tunbridge Wells Independent Speech and Language Therapy “TWIST”.
I operate a website at www.tunbridgewellspeechtherapy.co.uk
I am committed to protecting the privacy of any information provided to me, both for and by clients.
What information do I collect and why do I need it?
By accessing Lida Willingale/TWIST in the United Kingdom, I will collect and use information about you. This information includes your name, address, email, phone number and child’s information (e.g. date of birth, medical history)
The information that you provide when you register with Lida Willingale/TWIST is necessary so that I can enter you into a contract with me to enable me to provide relevant assessment, therapy, support and advice for your child.
Information about your child may be collected via spoken or written liaison with yourself as parents/guardians and/or your child. With parental consent, information may also be collected from other professionals working with the child/young person (e.g. teachers, Educational Psychologists, other Speech and Language Therapists). Information might also be collected about family members where this is pertinent to your child/young person (e.g. contact details and relevant medical or developmental history).
The www.twist.co.uk website can be used without providing any personal information.
Initial enquiries via telephone or email may lead to the recording/storing of personal information. If an enquiry does not result in your child/young person being seen by Lida Willingale then this information will be deleted once the enquiry has been dealt with.
The website contains links to other internet sites which are outside of my control and are not covered by this privacy policy. I am not responsible for data which you provide through any such linked websites.
When can I use your information?
I collect and use your information in the following situations: o Where use of your information is necessary for me to perform the contract or duty of care with you for your child. These include the Terms and Conditions of Therapy.
Where my use of your information is for one of “legitimate interest” under article 6 of GDPR and I have made sure that your information, and your rights in relation to the information, are protected. I cannot adequately deliver a service to your child/young person without processing their personal information. As it is both a necessity for my service delivery and a benefit to your child/young person, I have a legitimate interest to store his/her data.
Where I believe it is necessary to use your information to comply with a legal obligation to which I am subject.
Data relating to an individual’s health is classified as ‘Special Category Date’ under section 9 of 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 I process and store personal information.
Where I rely on consent to use your data, you have the right to withdraw that consent at any time. Please see ‘Your Choices and Rights’ section of this policy for more details.
Who is your personal information shared with?
Personal information collected via email, telephone or face-to-face contacts is stored and used by Lida Willingale for the purpose of delivering Speech and Language Therapy and providing assessment and advice.
Any sensitive personal details are stored in a secure confidential system, and processed in confidence by Lida Willingale, and are only be used for the purposes of delivering appropriate Speech and Language Therapy services.
With written consent, information about your child’s/young person’s speech, language and communication needs may be shared with other professionals involved in their care providing it is in their best interests e.g. nursery, school, GP, NHS services. A record of consent is kept within my case-notes.
Unless I am required to do so by law, I will not disclose any personal information collected to another person/professional other than as set out above. I will only share your information with any law enforcement agency, court, regulator, government authority or other third party where it is necessary to comply with a legal or regulatory obligation or otherwise to protest my rights or the rights of any third party.
Information on client location may be shared with a trusted person to ensure my personal safety when attending appointments.
I do not employ any agents to process personal data.
I do not give or sell client details to any third parties.
How do I use your personal information?
We, and other service providers (i.e. NHS, schools, nurseries etc) that I liaise with may use the personal information of your child/young person to: o Prepare, plan and provide targeted Speech and Language Therapy services appropriate to your child/young person’s needs.
Support meetings about your child/young person.
Help in accessing additional support (e.g. Specialist Teaching Service, onward referrals, Education Health and Care Plan).
Communicate with you as parents/guardians via email, telephone, mobile messages and SMS in relation to: - arranging and confirming appointments - general communication between appointments - sending summaries of therapy input, reports and programmes (password protected) - copying in to communications with other professionals - sending resources.
Carry out clinical audit to assess and improve my service. Results of any audits are always presented with all client identities removed.
Support my management and administration processes e.g. sending invoices and receiving payments
Whenever personal identifiers are not needed for the above tasks, they will be removed from the information used.
How do I store personal information?
All information about your child/young person and his/her Speech and Language Therapy is stored securely to ensure that I have a complete record of my service to them. I keep confidential notes on an online clinical portal which is password protected (or written notes prior to moving to the online system – in a secure locked cabinet) on each client in accordance with Data Protection Regulations.
Electronic information (e.g. reports and email correspondence) is stored on a password protected, single-user laptop.
Paper-based assessments are uploaded onto the online portal, but a paper copy retained until no further assessment is required and then shredded.
Notes are kept in a notebook following a visit with minimal information i.e. initials, date of visit. These are kept in a locked cabinet whilst not being accessed in accordance with Data Protection Regulations.
Films and audio recordings may be taken of clients with verbal/written consent. These are temporarily stored on a password protected smart phone. They may be used in order to inform assessment or used as a therapeutic tool. Recordings are deleted when they are no longer of clinical use to the SLT.
A minimal amount of confidential personal information will be physically taken out of my office. When taken away from the office it will be kept on my person or will be locked in the boot of my car.
How long do I store your child/young person’s information for?
I will keep your information for as long as is necessary for me to fulfil the purposes that are described in this policy. As a rule, however, I will keep; o The information you provide when you register with Lida Willingale/TWIST, together with any updates that are made to that information, for the duration of duty of care.
If you do not access therapy support for a period of 12 months I may, in accordance with data collection rules, deem your case to be inactive and suspend your child’s case. Your information will be kept and securely store for a further period of 12 months after which it will be deemed that your case is closed.
In accordance with guidelines from the Royal College of Speech and Language Therapists (RCSLT), all records will be kept securely until your child/young person reaches the age of 25 years. After this time, all records will be destroyed by shredding or deleting.
What are my Professional Obligations and Responsibilities?
It is a legal requirement for all Speech and Language Therapists practicing in the UK 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: o 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.hpc-uk.org/assets/documents/10002367finalcopyofscpejuly2008.pdf
I am committed to maintaining the security and confidentiality of all children/young people who are known to me in a professional capacity. I actively implement security measures to ensure their information is safe.
I am constantly working to ensure compliance with current data protection regulation.
What is UK Data Protection Law and EU General Data Protection Regulation?
Data Protection Law lays down wide-ranging rules, backed 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.
Lida Willingale is registered with the Information Commissioner’s Office (ICO) as a Data Controller. You can view my ICO registration by visiting: https://ico.org.uk/about-the-ico/what-we-do/register-of-fee-payers/download-the-register/
What are your Parent/Guardian Choices and Rights?
Data protection legislation gives you as a parent/guardian several rights in relation to your information and you can make several choices about how I collect and use it. For example, you can object to some of the ways in which we use your information.
Note that some of the choices or changes you make may impact my ability to maintain your case or provide you with a service and your account may need to be closed. I will notify you if such an action is necessary.
You can contact me regarding: o Updating, completing or correcting your contact and personal details we hold on you.
Instructing me on how you would like me to contact you relating to therapy matters. For example, via post, email, text, telephone.
o Instructing me of a third party you do not wish me to share your personal data or child’s information with.
Requesting access to the information I hold about you or your child/young person.
Asking that I amend a record if you believe there to be an error, erase or restrict my use of your information. This could impact on any therapy and may result in your child’s case being closed.
How do you access your child’s/young person’s records?
As a parent/guardian you can access the information I hold about your child/young person by email.
Access will be provided to the records within 30 days of receipt of all necessary information.
A copy of your child’s/young person’s records will be provided free of charge.
Please make a request via email to: lidawillingale@gmail.com
If there are further questions about how I collect, store and use personal data, please contact me at lidawillingale@gmail.com
Further information about data protection legislation and your rights as a service user is available from the Information Commissioner’s Office or by calling 0303 123 1113, 9am to 5pm, Monday to Friday.
