I (Carrie or Caroline Hughes) am an independent speech and language therapist working with children and adults, primarily in North East Essex and Suffolk, in both home and educational settings. I also create specialist speech therapy resources which are made available to other Speech and Language Therapists and others; primarily via the ‘carriehughes-slt.co.uk’ website, but also via other third party websites including, but not limited to ‘teacherspayteachers.com’

I am registered with the Health and Care Professions Council (HCPC). I am supported from time to time by associates such as student speech and language therapists, and other qualified speech and language therapists.

I am committed to protecting the privacy of information provided by clients.

Information about clients may be collected via spoken or written information from parents/carers. Information about clients may also be collected from other professionals working with clients (such as teachers, nursery staff, child-minders, NHS Speech and Language Therapists and other healthcare providers.

I may also collect information about family members where this relates to clients e.g. contact details for parents and relevant medical or developmental history.

You may access the carriehughes-slt.co.uk website (‘the 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 me to respond to your enquiry. You may add comments or queries which might also contain personal information.

If your enquiry does not result in a client being seen by Carrie Hughes or an associate then this personal information will be deleted once your enquiry has been dealt with. If Carrie Hughes or an associate subsequently sees the client, these details may be added to their personal record.

The Website contains links to other Internet sites that are outside my control and are not covered by this privacy policy. I am not responsible for data that you provide through any such linked sites.

Payments for purchases of resources made via the Website are fulfilled via PayPal. PayPal’s privacy policies may be located at https://www.paypal.com/gb/webapps/mpp/ua/privacy-full

“Our use of personal information” Other than in the case of ecommerce transactions, which are handled as described above, personal information collected via the Website, email, telephone or face to face, is stored and used for the purpose of delivering clients’ speech and language therapy.

Any sensitive personal details are stored in paper form and/or electronically in a secure and confidential system and processed in confidence and shall only be used for the purposes of delivering appropriate speech and language therapy services to clients.
With consent of clients or, in the case of minors, their parents or carers, information about clients’ speech and language needs may be shared with other professionals involved in clients’ care, when it is in a client’s best interests.

A record of consent is kept within clients’ case notes.

Unless I am required to do so by law, I will not disclose any personal information collected to any person other than as set out above. I do not employ agents to process personal data, for example specialist mailing companies to send out communications. I do not sell client details to any third parties and do not share details with third parties other than in the specific cases set out below.

I use this information:
•To prepare, plan and provide speech and language therapy services appropriate for clients’ needs
•To communicate via post, email, telephone, mobile messages, SMS and other messaging systems as may be available in relation to:
-confirming and preparing for appointments
-general communication in between appointments
-sending you reports and programmes for your child (always password protected)
-copying you in to communications with other professionals involved with the client
-sending you resources
-sending you invoices and receipts
•For clinical audit and professional supervision to assess and improve my service. Results of audits are always presented with all client identities removed
•For management and administration, for example surnames of clients are included in my password-protected accounting database

Whenever personal identifiers are not needed for these tasks, if possible I remove them from the information I use.

How I store personal information”

All information about clients and their speech and language therapy is stored securely in paper form or my IT systems to ensure that I have a complete record of my service to them. Primary appointment records are held in paper form. Other records, including but not limited to assessment reports are held electronically on a password-protected system, which is backed up to a further password-protected storage medium. Any paper based confidential information, such as assessments, is stored securely.

Videos may be taken of clients with their or their carers’ consent. These are temporarily stored on a password-protected tablet. These may then be viewed in order to make notes in a client record within 24 hours of the client’s appointment and to provide a basis for advice to parents and carers. The video is then deleted.

The minimum amount of confidential information will be taken out of the Speech and Language Therapist’s office base. When a client’s information is taken out of the office base it will be kept with the Speech and Language Therapist or will be locked in the Speech and Language Therapist’s alarm-protected car (whichever is deemed to be the most secure at that time).

In accordance with law, all records will be kept securely until your child is 25 years old. After this time all records relating to your child will be destroyed. Records relating to adults will be retained in accordance with Royal College of Speech and Language Therapists’ guidance.

Meeting my 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.

These standards affect the way in which I 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 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:
http://www.hcpc-uk.org/assets/documents/10004EDFStandardsofconduct,performanceandethics.pdf

UK Data Protection Law and EU General Data Protection Regulations lay down wide-ranging rules, backed up by criminal sanctions, for the processing of information about identifiable, living individuals. It also gives individuals certain rights in relation to personal data held about them by others. Carrie Hughes is registered with the Information Commissioner’s Office (ICO) as a Data Controller. You can view my ICO registration by visiting: https://ico.org.uk/ESDWebPages/Entry/ZA041267

My lawful basis for processing and storing personal information is one of ‘legitimate interest’ (under article 6 of GDPR).
I cannot adequately deliver a service to clients without processing their personal information. As it is both a necessity for our service delivery and of benefit to clients, I 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 I process and store personal information.

My responsibilities

I am committed to maintaining the security and confidentiality of clients’ records. I actively implement security measures to ensure their information is safe.

I will not release your personal details to any third party without first seeking your consent, unless this is allowed for or required by law.

I am constantly working to ensure compliance with current data protection regulation.

Your rights

Data protection legislation gives you, the client, or parent/carer of clients who are minors, various rights. The most important of these are as follows:
•You have the right to a copy of information I hold about you/your child
•You have the right to ask for your record to be amended if you believe that it is wrong.

How to access your client records

You can access the information I hold about you/your child by writing to me at the address given below. Please apply in writing rather than by email, so that I receive an original signature to compare against the records I hold. A copy of relevant records is provided free of charge.

I will provide access to your records within 30 days of receipt of all necessary information.
Please make your request in writing to:
Subject Access Requests
Carrie Hughes SLT
Wivenhoe, Colchester

If you have any further questions about how I use your information, please contact [email protected]

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.

Policy in effect from 25 May 2018.