Any information gathered is done so with you or your child’s best interests in mind so that Integrated Treatment Services can provide an efficient and effective service or work assignment.
All therapists have legal and professional obligations to keep accurate records relating to any treatment or services they provide.
Integrated Treatment Services has legal and professional obligations to keep accurate records relating to work assignments as provided to the locum therapist.
Integrated Treatment Services have access to contact details of prospective customers for marketing purposes – this data does not fall under GDPR restrictions as it does not apply to generic business data such as a school name or job title firstname.lastname@example.org or a postal mailing addressed to Head Teacher. No other marketing data is held, sold or purchased by Integrated Treatment Services.
Any information gathered by Integrated Treatment Services through any of the below communication channels will be relevant and not excessive; and will be adequate to meet the specified purpose of providing a good quality service for you (or your child) or your business. The basis for the processing of this data can be one or more of the legal basis in Appendix 1
When you contact us, whether by telephone, by post, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
We will never contact you unless to reply to your request, your information will not be held for marketing purposes.
You can at any point ask for you data to be removed from our secure email system.
If you send us information in connection with a job application or general careers enquiry, we may keep it for up to three years in case we decide to contact you at a later date.
You can at any point ask for you data to be removed from our secure email system.
If we contract you as a locum, we collect information about you and your work from time to time throughout the period of your work with us. This information will be used only for purposes directly relevant to your assignment. After your assignment has ended, we will keep your file for six years before destroying or deleting it.
Client records and case notes – read in conjunction with Sensitive Data policy The Royal College of Speech and Language Therapists (RCSLT) provide guidelines stating that it is good practice to ‘retain records for children and young people: up until their 25th birthday, or, until their 26th birthday if 17 at conclusion of their treatment’.
The RCSLT also advise that records are disposed of according to legal requirements and local policy as appropriate. Recent law: General Data Protection Regulations (GDPR) 2018 states that ‘personal data should not be kept in a form which permits identification of data subjects (child and parent) for longer than is necessary’. The GDPR also states that the data subject (child/parent) has the right to request erasure of personal data/information concerning him. Integrated Treatment Services must comply with this request if the data is no longer necessary in relation to the purposes for which it was collected if there are no overriding legitimate grounds for storing the data/information.
Integrated Treatment Services will destroy your child’s information after their 25th birthday, or their 26th birthday if 17 at conclusion of their treatment’. In the case of adults we will destroy your information 6 years after your last therapy input.
Relevant software used for information storage – links to privacy and security information
G Suite services for business – GMail (secure email system), Google Drive (secure cloud storage)
MNE accounts – accountants, users of Xero, Google Drive and GMail
Xero (secure accounting system) – see Appendix 2
STRIPE (card payment system)
Eventbrite – Training and event management
The bases on which we process information about you
GDPR requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
The following are the 4 defined bases that we can be processing your data under.
Information we process because we have a contract with you
When you become our client, a contract is formed between you and us.
The service we provide to you as a client necessarily entails you providing us with personal information.
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information generally use it to provide class information, for example to monitor the performance of a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our services, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information.
Sometimes you might give your consent implicitly, such as when you write to us requesting a response.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by writing to us at our registered office or by e-mail at email@example.com. If you do so, we shall not be able to provide our services further.
Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do so after having given careful consideration to:
- whether we could achieve the same objective by other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of our business
- protecting and asserting your rights, our rights, or the rights of any other third party
- insuring against or obtaining professional advice that is required to manage business risk
- protecting your interests where we believe we have a duty to do so
Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Information relating to your method of payment
Your debit or credit card number and other payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it. Your credit card data is held only within the Stripe or Eventbrite payment portals. See their privacy policies for further clarification.