We also consider carefully what information we need to keep; why we might need to keep it and whether there might be any (exceptional) situation where we might be required to share it. We are aware that you will need to be informed about our approach to the above in order to trust us.
You have rights and choices relating to your personal data and we aim to honour these and to respect your privacy at all times.
The following policy outlines what data we collect; where it is held and how it might be used. Sound Foundations Early Intervention & Psychotherapy Hub is registered as a data controller with the Information Commissioner’s Office under registration reference A8984341. The Data Protection Officer is Kathryn Cave.
Thank you for your interest in working with Sound Foundations Early Intervention & Psychotherapy Hub. We provide multi-model therapeutic & early intervention services for babies, children & adults with a range of diagnosed & undiagnosed needs.
We are registered with Companies House as a Community Interest Company (Reg. no: 13433934) with four directors. You can find more information about us from our website.
Our registered address is 60 Midland Road, Wellingborough, NN8 1LU.
Email: info@soundfoundations.org.uk
Website: www.soundfoundations.org.uk
This Statement was last updated on 21st June 2021 and the information set out here is in force from 25 May 2018. Any subsequent changes to any of the information set out here will be posted on our website.
Sound Foundations Early Intervention & Psychotherapy Hub holds personal data as part of conducting a professional service - under the following headings: healthcare records, educational records, clinical records, general administrative records, and financial records. We do collect and hold personal data for children and adults who receive our therapeutic services. This enables us to assess, audit and evaluate the work. It ensures best practice and enables our therapists to develop their skills in providing high standards of therapy. Information from referrals, assessments, meetings and sessions will be used to enable our team to write reports, liaise with families and professionals as required. Information may be shared within the team and to approved supervisors for educational purposes. We are professionally bound to keep accurate information and receive regular supervision by our profession specific regulatory bodies, the Health and Care Professions Council (HCPC), the British Psychological Society (BPS), The British Psychoanalytic Council (BPC) and the British Association for Counselling & Psychotherapy (BACP.) Data stored may be in the form of audio or video recordings, personal information, notes and reports.
We will only hold data and information for as long as reasonably necessary to carry out services, unless we are required to hold longer, for legal or professional reasons. For paper documents, they are stored in a locked filing cabinet. For electronic data, this is encrypted, held and stored securely. Data held may include:
· Name and address
· Email address and/or telephone numbers
· Date of birth
· Initial enquiry notes
· Referral information
· Correspondence through email or letter
· Assessment notes and Therapy reports
· Therapy session notes
· Therapy Sessions (Audio and Video Recordings)
For Online Therapy Sessions and Video Conferencing Sessions and Meetings:
· Online Therapy Sessions (Audio and Video Recordings)
· Names and Town locations of individuals connecting through Online therapy and Video Conferencing meetings
· Number of minutes used on Video conferencing meetings and Online Therapy Sessions
· Types of devices used to connect
· Dates, Times (join, leave and length times) and Meeting title information
· IP addresses of participants in Online Therapy sessions and Video Conferencing meetings
We will endeavour to:
· Communicate clearly about why we need to collect personal information and what we are going to use it for.
· Collect only the information we need.
· Take good care of all personal information, and make sure it is up to date, safe and secure.
We will never sell personal information, or let other organisations use it for marketing.
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. Due to the complex nature of many reasons for referral to therapy, 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. In order to provide a high quality service, a range of information may be collected.
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.
For child services:
· 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), Arts Therapies, Speech & Language Therapy, Occupational Therapy, Physiotherapy.
Relevant Individual Educational Plans (IEPs), progress notes from educational staff and school reports may be held.
Specific data in relation to therapy sessions may be collected and held, such as assessment forms, reports, case notes, e-mails, text messages and transcripts of phone calls. Audio and video files may also be collected and stored, with explicit consent from parents/carers.
Sound Foundations Early Intervention & Psychotherapy Hub may hold information regarding attendance reports and accident report forms.
A financial record pertains to all financial information concerning the practice, e.g. invoices, receipts, information for the Inland Revenue. We 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.
Personal data will be provided by the client, or in the case of a child (under 16 years), their 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.
Information may also be provided directly from relevant third parties such as schools, medical professionals and allied health professionals, with prior consent from the parent(s)/guardian(s).
Sound Foundations Early Intervention & Psychotherapy Hub uses the information collected to provide assessment and therapy as per the relevant professional guidelines, as well as to maintain the general running of the business, such as running an electronic booking system, keeping the accounts and updating you of any changes in policies or fees.
Information may also be used for research purposes, with the written consent of the client or parent/guardian.
The retention periods are the suggested time periods for which the records should be held based on the organisation’s needs, legal and/or fiscal precedence or historical purposes. Following the retention deadline, all data will be destroyed by confidential means.
· The preferred format for clinical data is electronic (writing up after the sessions). Any paper based data will be transferred to electronic means at the earliest convenience and then destroyed securely.
· Clinical data is deleted/confidentially destroyed after 7 years from last invoiced session. (Usually post discharge).
· Clinical data used for research purposes (if permission granted), may be kept for longer than 7 years.
· Video records/ audio recordings relating to client care/videoconferencing records 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.
· Financial Data is kept for 6 years to adhere to Revenue guidelines.
· Financial Data (including non-payment of bills) can be given to Revenue at Revenue’s request.
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.
Sound Foundations Early Intervention & Psychotherapy Hub do not share personal information with companies, organisations and individuals unless one of the following circumstances applies:
Sound Foundations Early Intervention & Psychotherapy Hub will only share your Personal Identifying Information (PII) to third parties when we have express written permission by letter or email to do so. We require opt-in consent for the sharing of any sensitive information.
Third parties may include: hospitals, GPs, other allied health professionals, educational facilities.
Sound Foundations Early Intervention & Psychotherapy Hub will share personal information with companies or organisations if disclosure of the information is reasonably necessary to:
§ Meet any applicable law, regulation, legal process or enforceable governmental request.
§ Meet the requirements of the Children First Act 2015.
§ To protect against harm to the rights, property or safety of my business, our service users or the public as required or permitted by law.
The following third parties are engaged for processing data:
Who Type of data Purpose
Electronic storage systems Notes/assessments/ Data storage
– Microsoft 365 Business personal Information
GoDaddy website personal information mailing list sign up
Prior to initial assessment, a copy of the data protection policy will be provided to clients when discussing the child’s case history. A consent form will need to be signed by the client prior to commencing the service. Copies of the signed consent forms will be given to both parties.
In accordance with the General Data Protection Regulation (GDPR), we will endeavour to protect your personal data in a number of ways:
All data collected by Sound Foundations Early Intervention & Psychotherapy Hub will be collected solely for the purposes set out above and will be collected for specified, explicit and legitimate purposes. The data will not be processed any further in a manner that is incompatible with those purposes save in the special circumstances referred to in section 6.2. Furthermore, all data collected will be adequate, relevant and limited to what is necessary in relation to the purposes for which it is collected which include, inter alia, the assessment and provision of early intervention and psychotherapeutic services.
Data will only be share and transmitted, be it on paper or electronically only as is required, and as set out in section 5.
We keep only data that is required and restrict its accessibility to any other third parties.
Within 7 years of the completion of this treatment apart from the special categories of personal data as set out at 3.1 above. Where data is required to be held for longer than the period 7 years Sound Foundations Early Intervention & Psychotherapy Hub will put in place appropriate technical and organisational measures to ensure a level of security appropriate to the risk. These may include measures such as the encryption of electronic devices, pseudonymisation of personal data, and/or safe and secure storage facilities for paper/electronic records.
Which, in this case, is 7 years post discharge except for circumstances in which retention of data is required in the circumstances set out at part 3.1 above or in certain specific circumstances as set out at Article 23(1) of the GDPR.
This could include the use of confidential shredding facilities or, if requested by the individual, the return of personal records to the individual.
For children under the age of 16, data access requests are made by their guardians. When a child turns 16, then they may make a request for their personal data. However, this is subject to adherence with the Children First Act.
Sound Foundations Early Intervention & Psychotherapy Hub take your privacy extremely seriously. As such, we aim to practice 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 collected, 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 possible, all physical files will be converted to electronic records.
Sound Foundations Early Intervention & Psychotherapy Hub understands that the personal data used in order to provide a service belongs to the individuals involved. The following outlines the steps which we use to ensure that the data is kept safe.
Copyright © 2023 Sound Foundations Early Intervention & Psychotherapy Hub - All Rights Reserved.
Community Interest Company No. 13433934