Introduction – Helen Harron is the Data Controller. The data controller supervises the compliance with the General Data Protection Regulation (GDPR) within the business. This Privacy Policy explains what Personal Data Seaside SaLT holds, why we hold and process it, who we might share it with and your rights and freedoms under the Law. Please contact us with any queries.
Seaside SaLT provides independent speech and language therapy to children in the home, clinical setting and/or educational setting. It is managed and co-owned by Helen Harron and Kate Hemingway, Speech and Language Therapists, who are registered with the Health and Care Professions Council (HCPC).
Seaside SaLT is committed to protecting the privacy of information provided by clients.
Our Lawful Basis For Processing Personal Information
Our lawful basis for processing and storing personal information is one of ‘legitimate interest’ (under article 6 of GDPR). We cannot adequately deliver a service to your child without processing their personal information. As it is both a necessity for our service delivery and of benefit to your child, we 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 we process and store personal information.
Our Professional Responsibilities
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.
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: www.hcpc-uk.org/assets/ documents/10004EDFStandardsofconduct,performanceandethics.pdf
Training
All members of staff complete annual mandatory training in GDPR, confidentiality and information governance.
1. Types Of Personal Data
Seaside SaLT 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.
1.1 Healthcare records
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, e.g., Specialist Advisory Teachers, Health Visitors.
- 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, Paediatricians, Specialist Advisory Teachers.
1.2 Educational records
Relevant Individual Educational Plans (IEPs), progress notes from educational staff and school reports may be held.
1.3 Clinical records
Specific data in relation to communication skills will be collected and held, such as assessment forms, reports, case notes, e-mails, text messages. Audio and video files may also be collected and stored.
1.4 General administrative records
Seaside SaLT may hold information regarding attendance reports and accident report forms.
1.5 Financial records
A financial record pertains to all financial information concerning the practice, e.g. invoices, receipts, information for HMRC. Seaside SaLT 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.
2. Where We Get Our Information
Personal data will be provided by a child’s (under 18 years) 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. Personal information may also be collected via the Seaside SaLT website, email, telephone or SMS.
With parental consent, information may also be collected from other professionals working with your child (such as teachers, nursery staff, childminders, NHS Speech and Language Therapists, Specialist Advisory Teachers). We may also collect information about family
members where this relates to your child e.g. contact details for parents and relevant medical or developmental history.
You may use the Seaside SaLT 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 us to respond to your enquiry. You may add comments or queries which might also contain personal information.
By providing personal information for initial contact by SMS, voicemail, phone call, email or website enquiry you are consenting to personal details for yourself and your child being held temporarily by Seaside SaLT. If your enquiry does not result in your child being seen by Seaside SaLT then this personal information will be deleted once your enquiry has been dealt with. If your child is subsequently seen by Seaside SaLT these details may be added to their personal record.
3. 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 keeping our accounts and updating you of any changes in policies or fees.
Examples of how we use this information:
- To prepare, plan and provide speech and language therapy services appropriate for your child’s needs.
- To communicate with you via post, email, telephone, mobile messages and SMS in relation to:
- confirming and preparing for appointments
- general communication in between appointments
- sending you reports and programmes for your child (which can be sent via encrypted email if you express preference on the consent form)
- copying you in to communications with other professionals involved with your child (your child’s initials, rather than full name will be used in emails) ○ sending you resources
- sending you invoices
- For clinical audit to assess and improve our service. Results of audits are always presented with all client identities removed.
- For management and administration, for example, names are used on invoices.
- Whenever personal identifiers are not needed for these tasks, if possible we remove them from the information we use.
Information may also be used for research and/or marketing purposes, with the written consent of the client or parent/guardian.
3.1 Data retention periods
Records relating to clients under the age of 18 must be kept by law until the client is 25. Following the retention deadline, all data will be destroyed under confidential means.
3.2 Client Records
3.2.1 Clinical Records (including contact data)
Seaside SaLT keeps both physical and electronic records of clinical data in order to provide a service.
- Clinical data is deleted/confidentially destroyed once a child reaches the age of 25 years or 7 years after therapy has ceased for adults, whichever is the longer time.
- Video records/ voice recordings relating to client care 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.
3.2.2 Financial Records
Seaside SaLT keeps paper and electronic records of financial data from those who use our services.
- Financial Data is kept for 6 years to adhere to HMRC guidelines. These requirements apply to manual and electronic records equally.
- Financial Data (including non-payment of bills) can be provided at HMRC’s request.
3.3 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.
4. Information We Share
We do not share personal information with companies, organisations and individuals outside Seaside SaLT unless one of the following circumstances apply:
4.1 With your consent:
We will only share your Personal Identifying Information (PII) to third parties when we have written permission. We require opt-in consent for the sharing of any sensitive information.
Third parties may include: hospitals, GPs, Specialist Advisory Teachers, Educational Psychologists, other allied health professionals, educational facilities.
4.2 For legal reasons:
We will share personal information with companies or organisations outside of Seaside SaLT if disclosure of the information is reasonably necessary to:
- Meet any applicable law, regulation, legal process or enforceable governmental request.
- Please note that if information is disclosed which relates to a child protection issue it is the duty of care of the professional to disclose this information to the appropriate authority in accordance with the Safeguarding Children Act 2004.
- To protect against harm to the rights, property or safety of Seaside SaLT, our service users or the public as required or permitted by law.
4.3 To meet financial requirements:
Seaside SaLT is also required to share financial data with Asquiths Accountants/ HMRC in order to comply with tax laws. Seaside SaLT is aware of Asquith’s own Data protection policy.
5. How And When We Obtain Consent
Prior to initial assessment or consultation, self funded clients will be provided with the Seaside SaLT Terms and Conditions. Clients referred to our school service can access copies of our policies on request. A consent form will need to be signed by parents/guardians prior to commencing the service or at the start of the initial consultation (see attached consent form). Copies of the signed consent forms will be stored securely in a locked filing cabinet and scanned and stored electronically with the child’s records.
Should a client wish to withdraw their consent for data to be processed, they can do so by contacting Seaside SaLT at any time.
6 Data Security
Seaside SaLT is aware of the need for privacy. As such, we aim to practise 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 used by Seaside SaLT, 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 applicable, Seaside SaLT may convert physical files to electronic records to allow us to provide a better service to clients.
6.1 Data Ownership
Seaside SaLT understands that the personal data used in order to provide a service belongs to the individuals involved. The following outlines the steps which Seaside SaLT uses to ensure that the data is kept safe.
6.1.1 Physical Files
All information about you, your child and their speech and language therapy is stored securely in our systems to ensure that we have a complete record of our service to them. All confidential information, including written case notes (summarising direct and indirect contact, such as content of therapy sessions, telephone calls etc), informal and formal assessments, paper copies of letters, reports and emails are stored securely, in accordance with Data Protection Regulations, in a lockable filing cabinet at Unit 15 Yorkshire Enterprise Centre, Auborough Street, Scarborough YO11 1HT. Only members of Seaside SaLT staff have access to these records.
The minimum amount of confidential information will be taken out of the Speech and Language Therapist’s office base.
6.1.2 Electronic Data
Documents which contain confidential information, such as reports and programmes, are also stored in a cloud based electronic storage system. This is password-protected.
Client phone numbers may be stored on a mobile telephone and text messages sent to Seaside SaLT may remain on the telephone. Seaside SaLT will only refer to your child by initial or first name in text. The mobile phone is passcode protected.
Videos/ Audio recordings may be taken of clients with parental consent. Where possible
these will be taken and stored on devices owned by parents/guardians. If this is not possible, a password protected device owned by Seaside SaLT will be used. The videos may then be viewed by the therapist in order to make notes in a client record or be used as part of therapy. The video will then be deleted when it is no longer required.
Photographs may be used for marketing purposes and shared on Seaside SaLT’s social media channels. This will be with explicit written consent of parents and guardians taken at initial referral; and then re-checked before the item is used.
Electronic data is contained in the following system, provided by Sensible IT Solutions:
6.2 Security Policy
6.2.1 Seaside SaLT understands that requirements for electronic and physical storage may change with time and the state of the art. As such, the managing directors reviews the electronic and physical storage options available annually.
6.2.2 Seaside SaLT is aware of and refreshes the requirements for good data hygiene regularly. This includes, but is not limited to:
- Awareness of client conversations in unsecure locations.
- Enabling auto-lock on devices when leaving them unattended, even within Seaside SaLT locations.
- Use of non-identifiable note taking options. (initials, not names).
- A procedure should a possible data breach occur, either through malicious (theft) or accident (loss) of devices or physical files.
7. Your Rights
Data protection legislation gives parents/guardians various rights. The most important of these are as follows:
- You have the right to be informed about the personal data we hold and why we hold it.
- You have the right to access a copy of your/your child’s data that we hold by contacting us directly.
- You have the right to ask for your record to be amended if you believe that it is wrong.
- You have the right to have your data erased in certain circumstances.
- You have the right to transfer your data to someone else if you tell us to do so and it is safe and legal to do so.
- You have the right to tell us not to actively process or update your data in certain circumstances.
8. How To Access Your Child’s Data
Data access requests can be made by a child’s (under 18) parents/guardians at any time.
You can access the information we hold about you by writing to us at the address given below. Please apply in writing rather than by email, so that we receive an original signature to compare against the records we hold.
A copy of your child’s records is provided free of charge.
We will provide access to your child’s records within 30 days of receipt of all necessary information.
Please make your request in writing to:
Seaside SaLT
℅ 32 Cornelian Avenue
Scarborough
N Yorks
YO11 3AW
If you have any further questions about how we use your information, please contact: helen@seasideslt.co.uk
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.
Date of document: October 2025
Review Date: October 2027
