Privacy Policy
When you use The Freeman Speech Practice Limited you trust us with your personal information. The processing of personal data is governed by the General Data Protection Regulation (GDPR). In compliance with GDPR, this privacy policy explains what personal information or data we collect from you when you visit our website or
are a recipient of our services. It also outlines why we collect it and what we do with it.
The Freeman Speech Practice is committed to processing personal information about its clients in ways that comply with its legal and regulatory obligations, and to being clear with clients about what it does with their personal information. The aim of this policy is to make this as simple as possible but if you have any questions please do contact us.
The Freeman Speech Practice Limited
The Freeman Speech Practice Limited is the data controller which means it decides how your personal data is processed and for what purpose.
The Freeman Speech Practice Limited is registered with Companies House – no. 09052308. The Freeman Speech Practice Limited delivers independent speech and language therapy services to adults in their own home, residential or nursing homes, or other settings where support with communication and/or swallowing is required.
It is owned and directed by Ruth Freeman, Speech and Language Therapist, who is registered with the Health and Care Professions Council (HCPC), the statutory regulator for Speech and Language Therapy.
The Freeman Speech Practice Limited is registered with the Information
Commissioner’s Office (ICO) as a Data Controller.
Data Collection
Personal data relates to a living individual who can be identified from that data. The Freeman Speech Practice Limited holds personal data as part of conducting a professional service. Personal information may be collected when:
• You use our website
• You use our services
• You contact us or
• You are a recipient of our services
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 difficulties 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.
The following types of information may be collected:
• Contact details such as: your name, home address, telephone number(s), email address
• Personal details such as: date of birth, medical history, nature of your speech and language difficulties
• Next of kin or family member details such as: their names, home addresses, telephone numbers, email addresses
• Other contact details such as: name and contact details for your General Practitioner (GP) and any other relevant health or social care professionals involved
Information is collected:
• via the website, email, telephone calls, face to face communication.
• Information required to provide you with Speech and Language Therapy services will be collected via spoken or written means from you, your family members, carers, and other professionals.
We are committed to keeping your information up to date as far as is reasonably possible. However, if you believe that we have made an error, then please contact us and we will use reasonable endeavours to correct.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the time you are receiving Speech and Language Therapy intervention.
How is this information used?
Your personal information is collected to:
• Provide you with services that you may request from us
• Meet our legal and regulatory obligations
Personal information is stored and used to:
• Plan and provide speech and language therapy services to you
• Communicate with you via telephone, email and post to
o arrange appointments
o liaise between appointments
o send you resources
o send you reports
o send you invoices and receipts
• For evaluation of the service provided by The Freeman Speech Practice Limited
• For management and administration of The Freeman Speech Practice Limited
How is my personal information stored?
The Freeman Speech Practice Limited complies with its obligations under the GDPR by keeping personal data up to date, by storing and destroying it securely, by not collecting or retaining excessive amounts of data, by protecting data from loss, misuse, unauthorised access and disclosure and by ensuring that the appropriate
technical measures are in place to protect your personal data.
The Freeman Speech Practice Limited stores personal information in paper and electronic formats.
Electronic format: Information about you and your speech and language therapy is stored securely so that we have a complete record of service. A secure web-based practice management system called ‘WriteUpp’ is used which is compliant with the
general data protection regulations. Documents containing your personal information may be temporarily stored on a laptop which is encrypted and password protected. When not in use, the laptop is stored in a locked filing cabinet.
Paper format: Documents containing your personal information are stored in a locked filing cabinet in accordance with data protection regulations. Some paper records are electronically scanned and then stored as part of the ‘Writeupp’ system detailed above.
The minimum amount of confidential information is taken out of the Speech and Language Therapist’s office. When it is taken out of the office, it is kept with Speech and Language Therapist at all times.
How long is personal information kept?
Telephone enquiry
For 4 months after the enquiry to allow for further contact and discussions that may occur. If a referral is made, the information may be transferred to the case notes otherwise the information will be destroyed.
Website enquiry
For 4 months after the enquiry to allow for further contact and discussions that may occur. If a referral is made, the information may be transferred to the case notes otherwise the information will be destroyed.
E-mail enquiry
For 4 months after the enquiry to allow for further contact and discussions that may occur. If a referral is made, the information may be transferred to the case notes otherwise the information will be destroyed.
Clinical notes
These are kept for as long as you are actively receiving Speech and Language Therapy intervention and for 8 years from the date of discharge or the date last seen in accordance with The Information Governance Alliance (2016) Records Management Code of Practice for Health and Social Care and professional guidance about information governance from the Royal College of Speech and Language Therapists. Once you have ceased Speech and Language Therapy intervention, your information will be archived and we will no longer actively process it.
After these timescales, your information will be securely destroyed.
Meeting our professional obligations
It is a legal requirement to be registered with the Health and Care Professions Council. HCPC has Standards of Conduct, Performance and Ethics to which all registrants must adhere. These standards affect the way in which therapists 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 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.”
Who is information shared with?
In order to manage and administrate The Freeman Speech Practice Limited, some external service providers are used. They may have access to some of your personal information in order that they can provide their services. These providers are:
IT company – If an IT issue occurs, it might be necessary for the relevant staff at the IT company to initiate a remote desktop connection. Their policy states that “this is only done with the explicit permission of the client and with the exclusive purpose of resolving the reported issue. The sessions are never recorded”. It is a rarity that this
would be required or that the IT staff would require access to emails or information temporarily stored on the hard drive of the laptop that would contain any of your personal information.
Writeupp – the web-based practice management system - Their terms and conditions state that the only staff who have access to any personal data are those involved with relevant procedures such as technical support and system administration and maintenance. The staff sign a confidentiality agreement and are trained about data security and patient identifiable information.
Unless we are required to do so by law, we will not disclose any personal information collected to any person other than as set out within this policy.
The Freeman Speech Practice does not sell client details to any third parties.
What is the lawful basis for processing personal information?
The lawful basis for processing and storing personal information is ‘legal obligation’ under article 6 of the GDPR. The Health and Care Professions Council Standards of Proficiency are based in law. The HCPC was established to regulate healthcare professionals in 2002 in accordance with the Health Professions Order in 2001 which was made under Section 60 of the Health Act 1999. Without holding the data we cannot work effectively.
Information relating to an individual’s health is classified as ‘special category data’ under section 9 of the GDPR. The regulations state that health professionals who are “legally bound to professional secrecy” may have a lawful basis for processing this information. Speech and Language Therapists are legally bound to keep client information confidential and it is under this condition that personal information is stored and processed by The Freeman Speech Practice Limited.
Your rights
Data protection legislation gives you various rights. These include:
• You have the right to a copy of the information we hold about you.
• You have the right to ask for your record to be amended if you believe that it is wrong.
How to access your records
You can access the information that The Freeman Speech Practice holds about you by contacting us at: ruth@freemanspeechpractice.co.uk. A postal address can be supplied upon request.
A copy of your records is provided free of charge. Access to your records will be provided within 30 days of receipt of all necessary information.
Changes to the Privacy Policy
This privacy policy is under regular review. It is likely to be updated as further information and advice about GDPR is provided. The latest version of the policy can be found at www.freemanspeechpractice.co.uk or by contacting Ruth Freeman at The Freeman Speech Practice Limited.
Questions
Please contact Ruth Freeman by:
Email: ruth@freemanspeechpractice.co.uk
Telephone: 0121 289 3839
Post: A postal address can be supplied upon request.
Further information about data protection and your rights is also available from The Information Commissioner’s Office (ICO) – www.ico.org.uk