Privacy Policy

This privacy policy explains how the information collected about you is stored and used when you employ ACT for Yorkshire Ltd. to provide Independent Speech & Language Therapy.

ACT for Yorkshire Ltd. has always taken the protection of client data very seriously and follows guidelines from two professional bodies (The Royal College of Speech & Language Therapists and The The Health & Care Professions Council) and from the UK’s independent authority: the Information Commissioners Office. The information contained within this privacy policy is a requirement of the General Data Protection Regulation (GDPR) legislation; which replaced the Data Protection Act with effect from 25th May 2018.

What is your lawful basis for processing my data?

ACT for Yorkshire Ltd. process your personal data under the lawful basis of ‘legitimate interests’ (GDPR Article 6-1-f). As with any healthcare provider, when you employ the services of ACT for Yorkshire Ltd., there is an implied understanding that relevant information is required to assess and treat you safely and appropriately.

Additional rules that require a higher degree of protection apply to the health information held about you because this is classed by law as ‘special category’ data. ACT for Yorkshire Ltd. processes your healthcare data under the lawful basis of ‘the provision of health or social care or treatment’ (GDPR Article 9-2-h). We are legally permitted to store and use your health data and communicate this with other professionals involved in your care for health-related purposes (assessment, diagnosis, and treatment) because we are bound by the confidentiality rules of our Professional bodies (The Royal College of Speech & Language Therapists and the The Health & Care Professions Council).

What data do you collect about me and why?

ACT for Yorkshire Ltd. will collect different data in order to assess, diagnose and provide appropriate treatment for you. Data may be given by you or by other people and can include the following:

• Personal information e.g. name, address, date of birth
• Health information e.g. medical history
• Email addresses
• Telephone numbers
• Correspondence e.g. clinical letters and reports, print outs of emails
• Assessment forms/results
• Clinical observations
• Audio / video recordings
• Photographs e.g. for use in communication apps and naming practice
• Financial information e.g. bank sort code and account number
• Private insurance policy details
• Contact details for family members (*)

(*) Please note that the names and contact details about any family member forms part of the data held about you so is treated the same in terms of confidentiality and security.

Information may be given verbally or in writing by you, your family/carer, your GP or Medical Consultant, another healthcare professional involved in your care, your employer, your case manager or legal team, your private health insurer, volunteer workers, University staff, SLT students or your NHS Trust.

ACT for Yorkshire Ltd. has a professional and legal duty to ensure that the information we record about you is relevant to your treatment/care, accurate and up to date, and only used for the purposes for which it was collected. Please help keep the records up to date by informing us of any changes e.g. you move house, change your telephone number or change your GP.

Where is my data kept?

Most of your data will be kept in your main clinical file but data may also be kept in the following places:

• Clinical diary
• Work mobile phone
• Electronic devices e.g. work i-Pad, laptop computers
• Removable media e.g. memory cards, memory sticks
• Invoices
• ACT for Yorkshire Ltd. bank statements
• i-Cloud storage
• Back up hard drives

How is my data secured?

ACT for Yorkshire Ltd. uses a series of measures to prevent theft, loss, damage or unauthorised access. These measures are checked regularly. All data is stored securely in locked filing cabinets when not in in use. When it is necessary to transport data about you (e.g. bringing your file to your clinic appointments), this will be kept with the therapist at all times. Wherever possible, data is anonymised using initials only to identify you. I-Pads and phones are pin protected. Laptops are password protected, data is encrypted as an additional security measure, and anti-virus software used to protect data from cyber-attack.

Who has access to my data?

Tessa Ackerman, the Director of ACT for Yorkshire Ltd. and any SLT employee or volunteer of the company would have access to your clinical data. The book-keeper and our firm of accountants will have access to your name and bank details for the purpose of maintaining the accounts and fulfilling HMRC requirements only. They have no access to your clinical file.

Who do you share my data with?

When providing healthcare, it is considered good practice to keep other people involved in your care updated. ACT for Yorkshire Ltd. may share your information with any of the following: your family/carer/friend, your GP or Medical Consultant, another SLT or healthcare professional involved in your care, your employer, your case manager or legal team, your private health insurer or your NHS Trust. We will normally get your verbal or written permission before sharing your information with other people. An exception to this would be when the law requires the information to be shared, or if you may be at risk if any concerns are not raised appropriately (e.g. legislation around issues of adult safeguarding). ACT for Yorkshire Ltd. will never sell or loan information about you to third party service providers and your data will not be exported outside of the U.K. unless you live abroad and give additional consent for this to happen.

How long do you keep data about me?

Professional guidelines require all Speech & Language Therapists (Independent or within the NHS) to retain clinical files and work diaries (containing contact information) for a period of 7 full years after discharge from our care. This is helpful if you need further treatment at a later date but is also a legal requirement. Financial records and items such as our bank statements (which may contain your name and bank details if you have made online payments) are also required to be kept for a full 7 year period by HMRC for tax purposes. Clinical discharges and accounts are shredded and destroyed by ACT for Yorkshire Ltd. annually in the January of each year, so the maximum your data would be kept is 7 years and 364 days unless you were re-referred to us during that period when the clock would re-set for the new episode of care.

Duplicate data (which also appears in your SLT file), such as your telephone number and email address will be deleted from electronic devices when you are discharged to reduce the possibility of a data breach if such devices are lost or stolen. The above requirements mean that your ‘right to be forgotten’ under GDPR law does not apply until we no longer have a need to keep your data for the reasons explained above.

If you make an enquiry about our service but for whatever reason do not subsequently arrange an assessment appointment, any written notes of telephone conversations with you, email correspondence and contact details will be deleted/shredded after a period of 3 months.

How can I access the information you hold about me?

ACT for Yorkshire Ltd. will keep you fully informed of every aspect of your care. You will routinely be given copies of any letters or reports which are written about you; unless there is a legal reason for us not to do so (e.g. adult safeguarding issues, police investigation, court evidence). You have the right to access your SLT file, but any request to do so must be made in writing. ACT for Yorkshire Ltd. reserves the right to charge a fee to cover the administrative cost of providing this information where it is requested more than once.

What happens if there is a breach of data about me?

ACT for Yorkshire Ltd. is required to inform you if the data breached about you could negatively affect your personal or professional life and is considered ‘a threat to your rights or freedoms’. We must also inform the Information Commissioner’s Office (I.C.O) within 72 hours of discovering such a breach. If you feel that your data protection rights have been breached by ACT for Yorkshire Ltd., you should raise your concerns with us in the first instance and we have 28 days in which to respond to your concerns. If you still feel that your concerns have not been satisfactorily addressed, you have the right to lodge an official complaint to the I.C.O. Details of how to do this can be found on www.ico.org.uk.

Changes to our privacy policy

The privacy policy is regularly reviewed, and the most recent copy can be accessed on the website: www.actforyorkshireltd.co.uk. This privacy policy was last updated on 29/06/2024.

Further information

If you have any questions about this privacy policy and how it applies to the information held about you, please contact Tessa Ackerman, the Director of ACT for Yorkshire Ltd. at the company’s registered address or on 07760 730 817 or tessa.act1@btinternet.com

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