1 .Introduction
This Privacy Policy describes the type of information that we collect from you through the use of our services, or the use of our website
lornamakatontutor.co.uk, how that information may be used or disclosed by us and the safeguards we use to protect it.
Our Website and Services may contain links to third party websites that are not covered by this Privacy Policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.
This Privacy Policy was last updated on 28th January 2020. Please check back regularly to keep informed of updates to this Privacy Policy. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Website. If you do not accept and agree with this Privacy Policy, you must stop using our Website immediately.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
If you have any comments on this Privacy Policy, please email them to info@lornamakatontutor.co.uk

2.Who We Are
2.1: Lorna Makaton Tutor provides Makaton support and Speech and Language Therapy to adults and children in Cumbria. Lorna Hutton is registered with the Information Commissioner’s Office (ICO) as a Data Controller.
Lorna Hutton assumes the function of data controller and supervises the compliance with the General Data Protection Regulation (GDPR) within the business. This Privacy Policy explains what Personal Data Lorna Makaton Tutor holds, why we hold and process it, who we might share it with and your rights and freedoms under the Law.
It is managed by Lorna Hutton, Speech and Language Therapist, who is registered with the Health and Care Professions Council (HCPC), is a
member of the Royal College of Speech & Language Therapists (RCSLT) and a member of the Association of Speech and Language Therapists in
Private Practice (ASLTIP).
- Our Website address is info@lornamakatontutor.co.uk
- Our email is info@lornamakatontutor.co.uk
- Our registered address is Bryn Howe Blindcrake Cockermouth CA130QP

2.2 We respect your right to privacy and will only process personal information you in accordance with the Data Protection Legislation.

3 What we collect
Our lawful basis for processing and storing personal information is one of ‘legitimate interest’ (under article 6 of GDPR). We cannot adequately deliver a service to your child without processing their personal information. As it is both a necessity for our 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.
Meeting our professional 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.
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:

www.hcpc-uk.org/assets/documents/10004EDFStandardsofconduct,performanceandethics.pdf 

3.1 Types of Personal Data Lorna Makaton Tutor 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.
i) Healthcare records
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, e.g., Specialist Advisory Teachers,
Health Visitors.
• 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, Paediatricians, Specialist Advisory Teachers.
ii) Educational records
Relevant Individual Educational Plans (IEPs), progress notes from educational staff and school reports may be held.
iii) Clinical records
Specific data in relation to communication skills will be collected and held, such as assessment forms, reports, case notes, e-mails, text messages. Audio and video files may also be collected and stored.
iv) General administrative records
Lorna Makaton Tutor may hold information regarding attendance reports and accident report forms.
v) Financial records
A financial record pertains to all financial information concerning the practice, e.g. invoices, receipts, information for HMRC. Lorna Makaton Tutor 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.

4. Where we collect our information
Personal data will be provided by a child’s (under 18 years) 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. Personal information may also be collected via the Lorna Makaton Tutor website, email, telephone or SMS. With parental consent, information may also be collected from other professionals working with your child (such as teachers, nursery staff,
childminders, NHS Speech and Language Therapists, Specialist Advisory Teachers). We 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.
You may use the Lorna Makaton Tutor website without providing any personal information. However, if you wish to make an enquiry via the
website, you are requested to provide relevant contact details, such as your name, e-mail address and contact telephone number to enable us to respond to your enquiry. You may add comments or queries which might also contain personal information.

By providing personal information for initial contact by SMS, voicemail, phone call, email or website enquiry you are consenting to personal details for yourself and your child being held temporarily by Lorna Makaton Tutor If your enquiry does not result in your child being seen then this personal information will be deleted once your enquiry has been dealt with. If your child is subsequently seen these details may be added to their personal record. 

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www.lornamakatonutor.co.uk website contains links to other Internet sites which are outside our control and are not covered by this Privacy Policy. We are not responsible for data which you provide through any such linked websites.

5. How we use information
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 keeping our accounts and updating you of any changes in policies or fees.
Examples of how we 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 (which will be password protected if sent via e mail)
• copying you in to communications with other professionals involved with your child (your child’s initials or first name, rather than full name will be used in emails)
• sending you resources
• sending you invoices
• For clinical audit to assess and improve our service. Results of audits are always presented with all client identities removed.
• For management and administration, for example, surnames are used on invoices. 

 

Whenever personal identifiers are not needed for these tasks, if possible we remove them from the information we use. Information may also be used for research purposes, with the written consent of the client or parent/guardian.

5.1 Data retention periods
Following the retention deadline, all data will be destroyed under confidential
means.

5.2 Client Records
5.2.1 Clinical Records (including contact data)
Lorna Makaton Tutor keeps both physical and electronic records of clinical data in order to provide a service.
• Clinical data is deleted/confidentially destroyed once a child reaches the age of 25 years or 7 years after therapy has ceased for adults,
whichever is the longer time.
• Video records/ voice recordings relating to client care 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.

5.2.2 Financial Records
Lorna Makaton Tutor keeps paper and electronic records of financial data from those who use our services.
• Financial Data is kept for 6 years to adhere to HMRC guidelines. These requirements apply to manual and electronic records equally.
• Financial Data (including non-payment of bills) can be provided at HMRC’s request.

5.3 Exceptions
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. 

 

6 Disclosure
We do not share personal information with companies, organisations and individuals outside Lorna Makaton Tutor unless one of the following
circumstances apply:

6.1 With your consent:
We will only share your Personal Identifying Information (PII) to third parties when we have written permission. We require opt-in consent for the sharing of any sensitive information. Third parties may include: hospitals, GPs, Specialist Advisory Teachers, Educational Psychologists, other allied health professionals, educational facilities.

6.2 For legal reasons:
We will share personal information with companies or organisations outside of Lorna Makaton Tutor if disclosure of the information is reasonably necessary to:
• Meet any applicable law, regulation, legal process or enforceable governmental request.
• Please note that if information is disclosed which relates to a child protection issue it is the duty of care of the professional to disclose this
information to the appropriate authority in accordance with the Safeguarding Children Act 2004.
• To protect against harm to the rights, property or safety of Lorna Makaton Tutor, our service users or the public as required or permitted by
law.

7 How and when we gain consent
Prior to initial assessment or consultation, clients will be provided with a summary privacy policy and Lorna Makaton Tutor Terms and Conditions. Parents/guardians will also be made aware of this full privacy policy available at www.lornamakatontutor.co.uk. A consent form will need to be signed by parents/guardians prior to commencing the service or at the start of the initial consultation. Copies of the signed consent forms and terms and conditions will be given to both parties.
Should a client wish to withdraw their consent for data to be processed, they can do so by contacting Lorna Makaton Tutor at any time.

8 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:
8.1 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. 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 the assessment, diagnosis and treatment of speech, language and communication disorders.

8.2 By transmitting the data in certain specified circumstances only Data will only be share and transmitted, be it on paper or electronically only
as is required, and as set out in section 3. 

 

8.3 By keeping only the data that is required when it is required and by limiting its accessibility to any other third parties.

8.4 By disposing of/destroying the data once the individual has ceased receiving treatment Section 5 outlines retention periods for different kinds of data. We will put in place appropriate technical measures to ensure a level of security appropriate to the risk. These will include measures such as safe and secure storage facilities for paper/electronic records. 

 

8.5 By retaining the data for only as long as is required which in this case is until a child reaches 25 years or 7 years after therapy has ceased for adults, whichever time is longer, except for circumstances in which retention of data is required in certain specific circumstances as set out
at Article 23(1) of the GDPR.

8.6 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.

8.7 By ensuring that any personal data collected and retained is both accurate and up-to-date.

9 Protecting your rights to data
Data access requests can be made by a child’s (under 18) parents/guardians.

10 Security
Lorna Makaton Tutor , as with most providers of healthcare services, is aware of the need for privacy. As such, we aim to practise privacy by design as a default approach, and only obtain and retain the information needed to provide you with the best possible service.
All data used by Lorna Makaton Tutor , 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, Lorna Makaton Tutor may convert physical files to electronic records to allow us to provide a better service to clients.

10.1 Data Security
Lorna Makaton Tutor understands that the personal data used in order to provide a service belongs to the individuals involved. The following outlines the steps which Lorna Makaton Tutor uses to ensure that the data is kept safe.

10.1.1 Physical Files
All information about you, your child and their speech and language therapy is stored securely in our systems to ensure that we have a complete record of our service to them. All confidential information, including written case notes (summarising direct and indirect contact, such as content of therapy sessions, telephone calls etc), informal and formal assessments, copies of letters, reports and e-mails are stored securely, in accordance with Data Protection Regulations, in individual client files at Bryn Howe, Blindcrake, Cockermouth, CA130QP in a lockable filing cabinet. Only Lorna Hutton has access to these records.

10.1.2 Electronic Data
Documents which contain confidential information, such as reports and programmes, are also stored on a password-protected laptop. Client phone numbers may be stored on a mobile telephone and text messages sent to JAS Speech and Language Therapy may remain on the
telephone. JAS Speech and Language Therapy will only refer to your child by initial or first name in text. The mobile phone is passcode protected.
 

11 Your rights
Data protection legislation gives parents/guardians various rights. The most important of these are as follows:
• You have the right to be informed about the personal data we hold and why we hold it.
• You have the right to access a copy of your/your child’s data that we hold by contacting us directly.
• You have the right to ask for your record to be amended if you believe that it is wrong.
• You have the right to have your data erased in certain circumstances.
• You have the right to transfer your data to someone else if you tell us to do so and it is safe and legal to do so.
• You have the right to tell us not to actively process or update your data in certain circumstances.

12 How to access your child’s data
You can access the information we hold about you by writing to us at the address given below. Please apply in writing rather than by email, so that we receive an original signature to compare against the records we hold. A copy of your child’s records is provided free of charge.
We will provide access to your child’s records within 30 days of receipt of all necessary information.
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.