Marukh Rehman (Owner) assumes the function of data controller and supervises the compliance with General Data Protection Regulation (GDPR) within the business.
- Information we collect
- Where we get our information
- How we use the information we collect
- Information we share
- How and when consent is obtained
- How we protect your data
- Protecting your rights to data
- Security of your personal data
1 Information we collect
Morph & Bloom Communication Therapy holds personal data as part of conducting a professional service. The data follows under the following headings: healthcare records, educational records, clinical records, general administrative records, and financial records.
1.1 Healthcare records
A healthcare record refers to all information collected, processed and held both in manual and electronic formats pertaining to the service user and their care. Speech and language problems can be complex, and a wide range of information may be collected in order to best meet the needs of the client, and to maintain a high quality service which meets best practice requirements. In order to provide a high quality service, a range of information may be collected.
Examples of data collected and held on all current and active clients include the following:
- Contact details: Name, address, phone numbers, e-mail address.
- Personal details: date of birth.
- Other contacts: name and contact details of GP and any other relevant healthcare professionals involved.
For child services:
- Parent/guardian details
- Description of family
- Educational placements.
- Pre- and post-natal history: This can include information relating to mother’s pregnancy, and child’s birth.
- Developmental data: developmental milestones, feeding history, audiology history.
- Medical details: such as any relevant illnesses, medications, and relevant family history. Reports from other relevant allied health professionals such as: Audiology, Psychology, CAMHS (Child & Adolescent Mental Health Services), Occupational therapy, Physiotherapy, Ophthalmology.
1.2 Educational records
Relevant Individual Educational Plans (IEPs), progress notes from educational staff and school reports may be held.
1.3 Clinical records
Specific data in relation to communication skills may be collected and held, such as assessment forms, reports, case notes, e-mails, text messages and transcripts of phone. Audio and video files may also be collected and stored.
1.4 General administrative records
Morph & Bloom Communication Therapy may hold information regarding attendance reports and accident report forms.
1.5 Financial records
A financial record pertains to all financial information concerning the practice, e.g. invoices, receipts, information for Revenue. Morph & Bloom Communication Therapy may hold data in relation to: on-line purchasing history, card payments, bank details, receipts and invoices. Information will include name of bill payer, client name, address and record of invoices and payments made.
2 Where we get our information
Personal data will be provided by the client, or in the case of a child (under 16 years), their parent(s)/guardian(s). This information will be collected as part of a case history form prior to, or on the date of first contact.
Information may also be provided directly from relevant third parties such as schools, medical professionals and allied health professionals, with prior consent from the parent(s)/guardian(s).
3 How we use the information that we collect
We use the information we collect to provide assessment and therapy as per the relevant professional guidelines, as well as to maintain the general running of the business, such as running our electronic booking system, keeping our accounts and updating you of any changes in policies or fees.
Information may also be used for research purposes, with the written consent of the client or parent/guardian.
3.1 Data retention periods
The retention periods are the suggested time periods for which the records should be held based on the organisation’s needs, legal and/or fiscal precedence or historical purposes. Following the retention deadline, all data will be destroyed under confidential means.
3.2 Client Records
3.2.1 Clinical Records
3.2.2 Morph & Bloom Communication Therapy keeps both physical and electronic records of clinical data in order to provide a service.
- The preferred format for clinical data is paper.
- Clinical data is deleted/confidentially destroyed when the child reaches 25 years old.
- Video records/ voice recordings relating to client care/videoconferencing records may be recorded with consent, analysed and then destroyed. If written consent is provided to use recordings for training purposes, the client will have the option to withdraw consent at any time.
3.2.3 Financial Records
Morph & Bloom Communication Therapy keeps electronic/paper records of financial data from those who use our services.
Section 886 of the Direct Tax Acts states that the Revenue Commissioners require records to be retained for a minimum period of six years after the completion of the transactions, acts or operations to which they relate. These requirements apply to manual and electronic records equally.
- Financial Data is kept for 6 years to adhere to Revenue guidelines.
- Financial Data (including non-payment of bills) can be given to Revenue at Revenue’s request.
3.2.4 Contact Data
Contact Data is kept for 6 years to allow processing of Financial Data if required. (This may be retained for longer for safety, legal request, or child protection reasons.)
If under investigation or if litigation is likely, files must be held in original form indefinitely, otherwise files are held for the minimum periods set out above.
4 Information we share
We do not share personal information with companies, organisations and individuals outside Morph & Bloom Communication Therapy unless one of the following circumstances apply:
4.1 With your consent:
We will only share your Personal Identifying Information (PII) to third parties when we have express written permission by letter or email to do so. I require opt-in consent for the sharing of any sensitive information.
Third parties may include: hospitals, GPs, other allied health professionals, educational facilities.
4.2 For legal reasons:
We will share personal information with companies or organisations outside of Morph & Bloom Communication Therapy if disclosure of the information is reasonably necessary to:
- Meet any applicable law, regulation, legal process or enforceable governmental request.
- To protect against harm to the rights, property or safety of Morph & Bloom Communication Therapy our service users or the public as required or permitted by law.
4.3 To meet financial requirements:
Morph & Bloom Communication Therapy also is required to share Financial data with an accountant in order to comply with local tax laws. Morph & Bloom Communication Therapy IS OBTAINING a copy of the accountant’s own Data protection policy.
4.4 For processing by third parties/external processing
The following third parties are engaged for processing data:
|Who||Type of data||Purpose|
|Administrative staff||Record keeping, typing, correspondence.||Updating records|
|Accountant||Financial||Processing financial accounts|
|Electronic booking/ storage systems||Contact||Contact details|
5 How and when we obtain consent
Prior to initial assessment or consultation, a copy of the data protection policy will be provided to clients along with a consent form (referral form). A consent form will need to be signed by the client prior to commencing the service. Copies of the signed consent forms will be given to both parties.
Should a client wish to withdraw their consent for data to be processed, they can do so in writing and send this to Morph & Bloom Communication Therapy (via post/email).
6 How we protect your data
In accordance with the General Data Protection Regulation (GDPR), we will endeavour to protect your personal data in a number of ways:
6.1 By limiting the data that we collect in the first instance
All data collected by us will be collected solely for the purposes set out at 1 above and will be collected for specified, explicit and legitimate purposes. The data will not be processed any further in a manner that is incompatible with those purposes save in the special circumstances referred to in section 5.1.
Furthermore, all data collected by us will be adequate, relevant and limited to what is necessary in relation to the purposes for which it is collected which include, inter alia, the assessment, diagnosis and treatment of speech, language and communication disorders.
6.2 By transmitting the data in certain specified circumstances only
Data will only be share and transmitted, be it on paper, electronically or via telephone only as is required, and as set out in section 3.
6.3 By keeping only the data that is required
When it is required and by limiting its accessibility to any other third parties.
6.4 By retaining the data for only as long as is required
Which in this case is until the child is 25 years old as set out by GDPR.
6.5 By destroying the data securely and confidentially after the period of retention has elapsed.
This could include the use of confidential shredding facilities or, if requested by the individual, the return of personal records to the individual.
6.6 By ensuring that any personal data collected and retained is both accurate and up-to-date.
7 Protecting your Rights to Data
For children under the age of 16, data access requests are made by their guardians. When a child turns 16, then they may make a request for their personal data. However, this is subject to adherence with the Children First Act.
Morph & Bloom Communication Therapy, as with most providers of healthcare services is aware of the need for privacy. As such, we aim to practice privacy by design as a default approach, and only obtain and retain the information needed to provide you with the best possible service.
All persons working in, and with Morph & Bloom Communication Therapy in a professional capacity are briefed on the proper management, storage and safekeeping of data.
All data used by Morph & Bloom Communication Therapy, including personal data may be retained in any of the following formats:
1. Electronic Data
2. Physical Files
The type of format for storing the data is decided based on the format the data exists in.
Where applicable, Morph & Bloom Communication Therapy may convert physical files to electronic records to allow us to provide a better service to clients.
8.1 Data Security
Morph & Bloom Communication Therapy understands that the personal data used in order to provide a service belongs to the individuals involved. The following outlines the steps which Morph & Bloom Communication Therapy use to ensure that the data is kept safe.
8.1.1 Electronic Data
All electronic data is contained in the following systems: (Copy / Paste for each system).
e.g. Email system, CMS, shared folders, etc.
- This system is physically located in the UK.
- This system provider is aware of their requirements for GDPR compliance.
- The system has an EXTERNAL administrator / Database owner. The External administrator does not have access to client records.
- This system HAS a Live Update for security enabled.
- All persons working in Morph & Bloom Communication Therapy have READ access to records.
- All persons require a Log on and Password in order to access the records.
- A copy of the files ARE NOT made on the users’ computer when in use.
- The data controller in Morph & Bloom Communication Therapy CAN remove or delete users.
- The data controller in Morph & Bloom Communication Therapy CAN change users passwords.
8.1.2 Physical Files
All physical data is located in:
- This system is physically located at Old Police Station, 77 Mellor St, Rochdale, OL11 5BT.
- ALL persons working in Morph & Bloom Communication Therapy have access to these records.
- These records ARE kept in a container secured with a lock and key.
8.2 Security Policy
8.2.1 Morph & Bloom Communication Therapy understands that requirements for electronic and physical storage may change with time and the state of the art. As such, the data controller in Morph & Bloom Communication Therapy reviews the electronic and physical storage options available to Morph & Bloom Communication Therapy at the start of every financial year.
8.2.2 All physical devices used by persons working in Morph & Bloom Communication Therapy which may contain any identifiable PII ARE NOT enabled with loss theft tracking and remote wipe abilities.
8.2.3 All persons working in Morph & Bloom Communication Therapy are aware and briefed on and refresh the requirements for good data hygiene every 6 MONTHS. This briefing compliance is monitored by the Morph & Bloom Communication Therapy data controller and includes, but is not limited to:
- Awareness of client conversations in unsecure locations.
- Enabling auto-lock on devices when leaving them unattended, even within Morph & Bloom Communication Therapy locations.
- Use of non-identifiable note taking options. (initials, not names).
- The awareness of Morph & Bloom Communication Therapy procedure should a possible data breach occur, either through malicious (theft) or accident (loss) of devices or physical files.
Date of document: 19th February 2020
Review Date: April 2021