This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. This privacy notice applies to personal information processed by or on behalf of the Access Communication CIC.

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This Notice explains
• Who we are, how we use your information and our Data Protection Officer

• What kinds of personal information about you we process

• What the legal grounds are for our processing of your personal information (including when we share it with others)

• What you should do if your personal information changes

• How long your personal information is retained by us
• What your rights are under data protection laws

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The General Data Protection Regulation (GDPR) is a single EU-wide regulation on the protection of confidential and sensitive information. It became law on the 25th May 2018, and is to be read alongside the new UK Data Protection Act 2018.

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For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), and the Data Protection Act 2018, the Access Communication CIC responsible for your personal data is Access Communication CIC.

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This Notice describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you.

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Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.

Access Communication CIC is the ‘Controller’ of the personal data you provide to us. We collect basic personal data about you which does not include any special types of information or location-based information. This does however include name, address, contact details such as email and mobile number etc. We will also collect sensitive confidential data known as “special category personal data”, in the form of health information, the services we provide to you and or linked to your child’s Speech and Language Therapy or healthcare.

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Why do we need your information?

The Speech and Language Therapist and associates who provide you with care maintain records about your health and any treatment or care you have received previously (e.g. SLT reports, Educational Psychology or school reports, Medical reports etc.). These records help to provide you with the best possible SLT care.

Access Communication CIC records are a mixture of electronic and paper or both. We use a combination of working Access Communication CICs and technology to ensure that your information is kept confidential and secure.

Records which Access Communication CIC holds about you may include the following information;

• Details about you, and your child, such as your address, contact details

• Contact with you and your child, such as appointments
• Notes and reports about your health
• Details about your child’s SLT treatment and care

• Relevant information from other health and education professionals

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To ensure your child receives the best possible care, their records are used to facilitate the care they receive. Information may be used within Access Communication CIC for clinical audit to monitor the quality of the service provided.

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How do we lawfully use your data?

We need to know your personal, sensitive and confidential data in order to provide you with SLT services at Access Communication CIC, under the General Data Protection Regulation we will be lawfully using your information in accordance with: Article 6, e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;” Article 9, (h) processing is necessary for the purposes the provision of SLT and health care or treatment.

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How do we maintain the confidentiality of your records?

We are committed to protecting your privacy and will only use information collected lawfully in accordance with:

• Data Protection Act 2018
• The General Data Protection Regulation
• Human Rights Act 1998
• Common Law Duty of Confidentiality
• Health and Social Care Act 2012
• NHS Codes of Confidentiality, Information Security and Records Management

• Information: Every member of staff has a legal obligation to keep information about you confidential.

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We will only ever use or pass on information about you if others involved in your care have a genuine need for it.

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We will not disclose your information to any third party without your permission unless there are exceptional circumstances (i.e. life or death situations).

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Access Communication CIC policy is to respect the privacy of our patients, their families and our staff and to maintain compliance with the General Data Protection Regulations (GDPR) and all UK specific Data Protection Requirements.

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Our policy is to ensure all personal data related to our patients will be protected. All employees and sub-contractors engaged by our Access Communication CIC are asked to sign a confidentiality agreement. The Access Communication CIC will, if required, sign a separate confidentiality agreement if the client deems it necessary. If a sub-contractor acts as a data processor for Access Communication CIC an appropriate contract (art 24-28) will be established for the processing of your information.

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In certain circumstances you may have the right to withdraw your consent to the processing of data. Please contact the Data Protection Officer in writing if you wish to withdraw your consent. If some circumstances we may need to store your data after your consent has been withdrawn to comply with a legislative requirement.

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This information is not shared with third parties or used for any marketing and you can unsubscribe at any time via phone, email or by informing the Access Communication CIC DPO as below.

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Where do we store your information electronically?

Electronic notes are stored at 27 Rathfriland Road, Hilltown, BT34 5YB. No personal data is stored outside of the EU.

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How long will we store your information?

We are required under UK law to keep your information and data for the full retention periods as specified by the NHS Records management code of Access Communication CIC for health and social care and national archives requirements. More information on records retention can be found online at (https://digital.nhs.uk/article/1202/RecordsManagement-Code-of-Practice-for-Health- and-SocialCare-2016)

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How can you access, amend move the personal data that you have given to us?

Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

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Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.

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Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example for a research project), or consent to market to you, you may withdraw your consent at any time.

Right to rectification: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “rectify” your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply.

Right of access: Under the DPA and the GDPR you have the right to access the data we hold about you.

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Access to your personal information Data Subject Access Requests (DSAR): You have a right under the Data Protection legislation to request access to view or to obtain copies of what information Access Communication CIC holds about you and your child and to have it amended should it be inaccurate.

 

To request this, you need to do the following:

• Your request should be made to the Access Communication CIC in writing or verbally

There is no charge to have a copy of the information held about you providing it is a legitimate request and is the first request made.

• Once ID has been verified we are required to respond to you within one month

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What should you do if your personal information changes?

You should tell us so that we can update our records please contact us at info@accesscommunication.org.uk this is especially important for changes or address or contact details (such as your mobile phone number), the Access Communication CIC will from time to time ask you to confirm that the information we currently hold is accurate and up-to-date.

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Objections / Complaints

Should you have any concerns about how your information is managed at Access Communication CIC, please contact Access Communication CIC or the Data Protection Officer as below.

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You have a right to complain to the UK supervisory Authority as below. Information Commissioner’s Office
Wycliffe house
Water Lane

Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113 or 01625 545745 www.informationcommissioner.gov.uk

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If you are happy for your data to be extracted and used for the purposes described in this privacy notice, then you do not need to do anything. If you have any concerns about how your data is shared, then please contact Access Communication CIC.

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If you would like to know more about your rights in respect of the personal data we hold about you, please contact as below.

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Elaine Mc Greevy
Access Communication Ltd.
Email info@accesscommunication.org.uk
Address 27 Rathfriland Road, Hilltown, Newry, Co Down, BT34 5YN

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Changes: It is important to point out that we may amend this Privacy Notice from time to time. If you are dissatisfied with any aspect of our Privacy Notice, please contact Access Communication CIC.