Data Protection and Privacy Policy

Privacy Policy Statement for Limerick Speech & Language Therapy

When you use Limerick Speech and Language Therapy you trust us with your information. This privacy policy is meant to help you understand what data we collect, why we collect it, and what we do with it. We have tried to make it as simple as possible but if you have any questions please contact us. See contact details above.

Laura Hogan assumes the function of data controller and supervises the compliance with General Data Protection Regulation (GDPR) within the business.

 

  • Information we collect
  • Where we get our information
  • How we use the information we collect
  • Information we share
  • How and when consent is obtained
  • How we protect your data 
  • Protecting your rights to data
  • Security of your personal data
  • Information we collect

Limerick Speech & Language Therapy holds personal data as part of conducting a professional service. The data follows under the following headings: healthcare records, educational records, clinical records, general administrative records, and financial records.

 

  • Healthcare records

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 problems 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 that 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), Occupational therapy, Physiotherapy, Ophthalmology etc. 

 

For adult services:

  • Employment/vocational history
  • Family and social history
  • Mental health
  • Medical information: relevant medical conditions or illnesses, medications, letters/reports from relevant healthcare professionals, such as ENT, Neurology, Psychology etc.

 

  • Educational records

Relevant Individual Educational Plans (IEPs), progress notes from educational staff, school reports and clinical notes relating to liaison with educational staff (e.g. telephone conversations or staff-therapist meetings) may be held.

 

  • Clinical records

Specific data in relation to communication and/or eating, drinking and swallowing skills may be collected and held, such as assessment forms, reports, case notes, e-mails, text messages and transcripts of phone. Audio and video files may also be collected and stored.

 

  • General administrative records

Limerick Speech and Language Therapy may hold information regarding attendance reports and accident report forms.

 

  • Financial records

A financial record pertains to all financial information concerning the practice, e.g. invoices, receipts, information for Revenue. Limerick Speech & Language Therapy may hold data in relation to: attendance and payment 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.

  • Where we get our information

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).

  • How we use the information that we collect

We use the information we collect 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 our appointment booking system, keeping our 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.

  • Data retention periods

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 under confidential means.

 

  • Clinical Records

Limerick Speech & Language Therapy keeps both physical and electronic records of clinical data in order to provide a service.

  • The preferred format for clinical data is paper.
  • Clinical data is deleted/confidentially destroyed after 2 years from last session. (Usually post discharge).
  • Clinical data used for research purposes, may be kept for longer than 2 years.
  • Video records/ voice 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 Records
  • Limerick Speech & Language Therapy keeps electronic/paper records of financial data from those who use our services. 

 

  • Section 886 of the Direct Tax Acts states that the Revenue Commissioners require records to be 
  • retained for a minimum period of six years after the completion of the transactions, acts or
  • operations to which they relate. These requirements apply to manual and electronic records equally, 
  • as follows:
  • 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.

 

  • Contact Data

Contact Data is kept for 6 years to allow processing of Financial Data if required. (This may be retained for longer for safety, legal request, or child protection reasons.)

 

  • Exceptions

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. 

 

  • Information we share

We do not share personal information with companies, organisations and individuals outside Limerick Speech and Language Therapy unless one of the following circumstances apply: 

 

  • With your consent:

We will only share your personal information 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.

 

  • For legal reasons:

We will share personal information with companies or organisations outside of Limerick Speech and Language Therapy 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 safely of Limerick Speech and Language Therapy, our service users or the public as required or permitted by law. 

 

  • For processing by third parties/external processing:

The following third parties may be engaged for processing data:

 

Who

Type of data

Purpose

Administrative staff

Record keeping, typing, correspondence.

Updating records

Accountant

Financial

Processing financial accounts

 

  • How and when we obtain consent

For new clients, prior to first contact, a copy of the privacy policy will be provided to clients along with a client consent form and clients will be informed of the data protection policy available on request. A consent form will need to be signed by the client prior to commencing the service. Copies of the signed consent form will be given to both parties. 

 

For existing or returning clients, from January 7th 2020, a copy of the privacy policy will be provided to clients along with a client consent form and clients will be informed of the data protection policy available on request prior to their appointment. A consent form will need to be signed by the client prior to commencing any further service. Copies of the signed consent form will be given to both parties.

 

In cases where services from Limerick Speech & Language Therapy are obtained and provided to an individual on behalf of a service or organisation, such as a residential service, day-care service, school, pre-school, childcare setting or voluntary organisation, a copy of the privacy policy and a consent form will be provided to a person in authority at that service confirming that they have engaged our services on behalf of their client and consenting on behalf of their client to our data protection and privacy policy, and that they have provided their own privacy policy to the individual which includes consent that external suppliers may hold personal data.

 

Should a client wish to withdraw their consent for data to be processed, they can do so by contacting Limerick Speech & Language Therapy. You can find contact details on our website, www.slt.ie 

  • How we protect your data

In accordance with the General Data Protection Regulation (GDPR), we will endeavour to protect your personal data in a number of ways:

  • By limiting the data that we collect in the first instance 

All data collected by us will be collected solely for the purposes set out at 1 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 5.1. Furthermore, all data collected by us 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, diagnosis and treatment of speech, language and communication disorders.

 

  • By transmitting the data in certain specified circumstances only 

Data will only be shared and transmitted, be it on paper or electronically, only as is required, and as set out in section 3.

 

  • By keeping only the data that is required 

when it is required and by limiting its accessibility to any other third parties.

 

  • By disposing of/destroying the data once the individual has ceased receiving treatment 

within 2 years of the completion of this treatment apart from the special categories of personal data as set out at 1.1 above. Where data is required to be held by us for longer than the period of 2 years, we 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. 

 

  • By retaining the data for only as long as is required 

which in this case is 2 years except for circumstances in which retention of data is required in circumstances set out at part 1.1 above or in certain specific circumstances as set out at Article 23(1) of the GDPR.

 

  • By destroying the data securely and confidentially after the period of retention has elapsed.  

This could include the use of confidential shredding facilities or, if requested by the individual, the return of personal records to the individual.

  • By ensuring that any personal data collected and retained is both accurate and up-to-date.
  • Protecting your Rights to Data
  • Adult clients

Adults have the right to request data held on them as per article 15 of GDPR. A request must be made in writing. Further information regarding accessing your personal data are available in the document ‘Rights of Individuals under the General Data Protection Regulation’, downloadable from: www.gdprandyou.ie

  • Children 

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. 

  • Security

Limerick Speech Therapy is aware of the need for privacy. 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 persons working in, and with Limerick Speech & Language Therapy in a professional capacity are briefed on the proper management, storage and safekeeping of data. 

 

All data used by Limerick Speech & language Therapy, including personal data may be retained in any of the following formats:

  • Electronic Data
  • Physical Files

 

The type of format for storing the data is decided based on the format the data exists in.

Where applicable, Limerick Speech & Language Therapy may convert physical files to electronic records to allow us to provide a better service to clients.

 

  • Data Security

Limerick Speech & Language Therapy understands that the personal data used in order to provide a service belongs to the individuals involved. The following outlines the steps which Limerick Speech & Language Therapy use to ensure that the data is kept safe.

 

  • Electronic Data

All electronic data is contained in the following systems:

 

1. Email:
- This system is physically located in Ireland.

- This system provider is aware of their requirements for GDPR compliance.

- The system has an administrator who is external to Limerick Speech & Language Therapy, however this administrator does not have access to client records.

- This system has a Live Update for security enabled.

- All persons working in Limerick Speech & Language Therapy have READ/WRITE/ DELETE access to records.

- All persons require a Log on and Password in order to access the records.

- A copy of the files are not made on the users’ computer when in use.

- The data controller in Limerick Speech & Language Therapy can remove or delete users.

- The data controller in Limerick Speech & Language Therapy can change users passwords.

 

 2. Laptop Computer/WriteUpp Cloud based practice management system :
- This system is physically located in Ireland.

- The system has an administrator who is internal to Limerick Speech & Language Therapy.

- This system has a Live Update for security enabled.

- All persons working in Limerick Speech & Language Therapy have READ/WRITE/ DELETE access to records.

- All persons require a Password in order to access the records.

- A copy of the files are not made on the users’ computer when in use.

- The data controller in Limerick Speech & Language Therapy can remove or delete users.

- The data controller in Limerick Speech & Language Therapy can change users passwords.

 

  • Physical Files

All physical data is located in: 

 

Limerick Speech and Language Therapy

1 John's St.

Limerick

 

Only persons working in Limerick Speech & Language Therapy have access to these records. These records are kept in a container secured with a lock and key.

 

If necessary, a physical file may be transported from the above premises to an alternative site where speech and language therapy services may be provided from. This occurs where records are needed in another location for the purpose of provision of speech and language therapy. Every care is taken during this time to ensure the security, confidentiality and immediate return of the physical file to the above address.

 

  • Security Policy
  • Limerick Speech & Language Therapy understands that requirements for electronic and physical storage may change with time and the state of the art. As such, the data controller in Limerick Speech & Language Therapy reviews the electronic and physical storage options available to Limerick Speech & Language Therapy on an annual basis.
  • All physical devices used by persons working in Limerick Speech & Language Therapy which may contain any identifiable personal information are password protected. They are not enabled with loss theft tracking and remote wipe abilities.
  • All persons working in Limerick Speech & Language Therapy are aware of and briefed on the requirements for good data hygiene which is refreshed on an annual basis. This briefing compliance is monitored by the Limerick Speech & Language Therapy data controller and includes, but is not limited to:
  • Awareness of client conversations in unsecure locations.
  • Enabling auto-lock on devices when leaving them unattended, even within Limerick Speech & Language Therapy locations.
  • Use of non-identifiable note taking options. (initials, not names).
  • The awareness of Limerick Speech & Language Therapy procedure should a possible data breach occur, either through malicious (theft) or accident (loss) of devices or physical files. 

 

 

 

 

Date of document: June 2020

Review Date: May 2021