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 we will not be able to assess and treat you safely and appropriately unless you or others give us the relevant information to do so.
Additional rules; requiring a higher degree of protection apply to the health information we hold 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 own professional bodies (The Royal College of Speech & Language Therapists and The Health & Care Professions Council).
What data do you collect about me and why?
ACT for Yorkshire Ltd. will collect a variety of data which helps us assess, diagnose and provide treatment for you. Data may be given to us by you or 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 we hold about you so is treated the same in terms of confidentiality and security.
Information may be given to us verbally or in writing by you, your family/carer, your G.P 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.
We have 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 us to keep our records up to date by informing us of any changes e.g. you move house, change your telephone number or change your G.P.
Where is my data kept?
Most of your data will be kept in your main clinical file but data about you may also be kept in the following places:
- Clinical diaries
- Work mobile phones
- Electronic devices e.g. work i-Pads, laptop computers
- Removable media e.g. memory cards, memory sticks
- ACT for Yorkshire Ltd. bank statements
- i-Cloud storage
- Back up hard drives
How is my data secured?
ACT for Yorkshire Ltd. take the security of your data very seriously and employ 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, we anonymise data 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 we use anti-virus software to protect data from cyber-attack.
Who has access to my data?
Only Tessa Ackerman and Zoe Coates; the Directors of ACT for Yorkshire Ltd. have access. Regardless of whether you see one or both of us for your treatment, Tessa Ackerman and Zoe Coates both require access to your data. This enables us to have clinical discussions about your care, plan our working week in terms of our appointments, and run the business in terms of invoicing, accounting and fulfilling HMRC requirements.
Who do you share my data with?
When providing healthcare, it is considered good practice to keep other people involved in your care updated. We may share your information with any of the following: your family/carer/friend, your G.P 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. Wherever possible we will ask your permission before sharing your information with other people. The exceptions to this are if we are required to share the information by law, or we consider you to be at risk by not raising our concerns (e.g. legislation around issues of adult safeguarding).
ACT for Yorkshire Ltd. will never sell or loan information about you to 3rd party service providers and your data will not be exported outside of the UK. The only exception to this would be if you live abroad and give 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 requirement in case of litigation.
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 get back to us, any written notes of our 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 to us. ACT for Yorkshire Ltd. reserve 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. are 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 by us, 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.
Tessa Ackerman - 07760 730817 - firstname.lastname@example.org
Zoe Coates - 07767 601079 - email@example.com
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