Privacy & Cookies Policy
Talk Speech and Language Therapy Ltd.
1. Introduction
1.1 In this policy, "we", "us" and "our" refer to Talk Speech and Language Therapy Ltd. For more information about us, please refer to Section 11.
1.2 We respect you privacy and are committed to safeguarding the privacy of our website visitors and service users.
1.3 This policy applies where we are acting as a data controller either with respect to the personal data of our website visitors and/or our service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 COOKIES We use cookies on our website. Where those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website. For more information on our use of cookies, please refer to Section 8
1.5 By visiting any of our websites, submitting an enquiry via our website contact form/s or by providing us with any information about yourself or others via any other communication means, you are accepting and agreeing to the practices described in this policy.
1.6 In this policy, we are referring at all times to your data and/or the data of any person whom you have consent from, or legal authority to provide to us; e.g your child or other dependent where you have parental or legal responsibility. This includes data from third parties where you have given consent for those parties to share data directly with us, or where they are legally entitled to do so, either via explicit consent or professional obligation.
1.7 Our website may include links to third-party websites, plug-ins and applications including social media platforms. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or data handling processes. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. Credit
2.1 This policy was created using a template from SEQ Legal.
3. How we use your personal data
Personal data relating to an individual’s health is classified as ‘Special Category Data’, section 9 of the GDPR regulations. Health professionals who are ‘legally bound to professional secrecy’ may also have a lawful basis for processing or sharing data.
It is a requirement for all Speech and Language Therapists to be registered with the Health and Care Professions Council (HCPC). The HCPC has clear standards of performance, conduct and ethics, that all registrants must adhere to;
Standard 2 “You must share relevant information, where appropriate, with colleagues involved in the care, treatment or other services provided to a service user.”
Standard 10 “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.”
Our lawful basis for processing and storing data is one or both of ‘legitimate interest’ which includes our legal and professional obligations or ‘consent’. Legitimate interest means that we need to do so to operate our business, to provide our services to you at the required standard, or to meet the legal requirements for Speech and Language Therapists. Consent means that we will obtain your explicit consent. Each of the data categories described in section 3, specifies our lawful basis for sharing that data category.
3. Data Categories - In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.1 We may process data about your access and use of our website ("website usage data"). The website usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the website usage data is “Google analytics” and Squarespace. This website usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interest, namely monitoring and improving our website and services.
3.2 We may process your personal data, that you provide in the course of the use of, or submitting an enquiry about our services ("enquiry data"). The enquiry data may include; your name, e-mail address, contact telephone number, child or dependents name. The enquiry data may also include any additional personal or information provided by you using our website enquiry form or sending us emails, SMS or phone calls. The enquiry data may be processed for the purposes of offering relevant services to you. The legal basis for this processing is consent.
3.3 We may process information relating to transactions, including purchases of services, that you enter into with us or through our website ("financial data"). The financial data may include your contact details, your card details and any transaction details. The financial data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our business.
3.4 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
3.5 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include any information that you provide to us within the communication content. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and providing a service to you.
3.6 We may process your data contained within Healthcare Records, Clinical Records, Educational Records and associated record data ("record data"). The source of this data is from discussions with you in the course of us providing a service or any third party whom has either your consent, or a legal or professional obligation to directly share data with us. This data may be processed to enable us to provide our services and to assess and meet the needs of an individual. The legal basis for this processing is our legitimate interests, namely meeting the needs of clients, our legal obligations and performance of a contract between you and us.
3.65 We may process your data contained within any communication that you send to us, in relation to a job enquiry or application ("employment enquiry data").. The legal basis for this processing is consent and also our legitimate interests. We may collect;
Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
Personal details such as date of birth, gender and nationality;
CV’s or cover letters or any other supplementary document included as part of the application process where requested or not;
Information about your right to work in the UK;
Information regarding your work history, qualifications, professional memberships, education, experience, or employment references;
Video recordings such as those that may be submitted as part of the recruitment process;
Photographs if included on CVs or otherwise on supplementary document submitted as part of the recruitment process; and
The results of any DBS checks we complete as part of the recruitment process.
Any other personal data you choose to share with us during an enquiry or application process.
3.7 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.8 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.9 Please do not supply any other person's personal data to us, unless you have consent or parental / guardian / other legal rights to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.2 We may disclose your personal data to third parties which may include: hospitals, doctors, teachers, educational psychologists, other allied health professionals and educational facilities, insofar as reasonably necessary for providing our services, or where we are professionally / legally obliged to do so. The legal basis for this processing is both consent and legitimate interest.
4.3 Financial transactions relating to our website and any services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://www.izettle.com/gb/privacy-policy
4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal or professional obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. Retaining and deleting personal data
5.1 This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We keep both physical and electronic records of data, as appropriate, in order to provide a service.
5.4 We will will not retain your data for longer than we need it, or longer than we are legally obligated to:
(a) ‘enquiry data’ will be retained for a maximum period of 1 month following submission, unless your enquiry leads to us providing services to you, in which case it will be treated as record or correspondence data.
(b) ‘record data’ and ‘correspondence data’ is considered clinical data which we have a legal obligation to retain for a defined period. It is deleted or confidentially destroyed once an individual reaches the age of 25 years, or 7 years after our therapy or services have ceased for adults, whichever is the longer.
(c) Video or voice recordings may be recorded with explicit consent from you during the provision of our service, analysed and then destroyed within 1 month.
(d) ‘financial data’ will be retained for a minimum period of 6 years or as per HMRC guidelines updated from time to time.
(e) ‘employment enquiry data’. Generally, we will keep the majority of your information for the duration of the recruitment process plus an additional 12 months thereafter. If you are successful in your application, information collected as part of the recruitment process will be transferred to your employee file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.
5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. Amendments
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7. Your rights
7.1 In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. We may also charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
We may need to request specific information from you, to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We aim to respond to all legitimate requests within one month. Occasionally it may take us longer than a month, if your request is particularly complex or you have made a number of requests. Some of our confidential files are stored in specialist long term confidential data storage and may take time to retrieve. In this case, we will notify you and keep you updated.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation e.g. medical records; or for the establishment, exercise or defence of legal claims.
7.8 If you consider that our processing of your personal information infringes data protection laws, you have the right to lodge a complaint with the Information Commissioners Office.
7.9 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.10 You may exercise any of your rights in relation to your personal data by written notice to us at our registered address or by email using the address published on our website from time to time.
8. About Cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies that we use
For information about viewing the cookies dropped on your device, visit https://support.squarespace.com/hc/articles/360001264507#toc-check-your-cookies.
Functional and required cookies are always used, which allow Squarespace, our hosting platform, to securely serve this website to you. https://support.squarespace.com/hc/articles/360001264507#toc-analytics-and-performance-cookies
Analytics and performance cookies are used on this site, as described below, only when you acknowledge our cookie banner. We use analytics cookies to view site traffic, activity, and other data. https://support.squarespace.com/hc/articles/360001264507#toc-analytics-and-performance-cookies
10. Managing cookies
10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
10.2 Blocking all cookies will have a negative impact upon the usability of many websites.
10.3 If you block cookies, you will not be able to use all the features on our website.
11. Our details
11.1 This website is owned and operated by Talk Speech and Language Therapy Ltd
11.2 We are registered in England and Wales, registration number 08298785 and our registered office is at
Filwood Green Business Park
1 Filwood Park Lane
Bristol
BS4 1ET
11.3 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, using the contact number published on our website from time to time;
(d) by email, using the email address published on our website from time to time.
12. Data protection officer
12.1 Our data protection officer can be contacted by writing to this address:
Data Protection Officer
Talk Speech and Language Therapy Ltd
The Park Centre
Daventry Road
BS41DQ
ICO Registration Number: ZA765626
Last policy review and update: November 2023