Privacy Policy
The General Data Protection Regulation (GDPR) is concerned with the personal information about you/your child and how it is collected, stored and shared. Data is collected, stored and managed in accordance with the General Data Protection Regulation (GDPR) (2016) and the subsequent UK Data Protection Act (2018).
We aim to be as clear as we can about how and why we collect and use information about you/your child, so that you can be confident that your privacy is protected.
This policy describes how we manage your information when you use our services. It includes contact information that is used to communicate with you and organisations, as well as confidential data collected or generated by our practitioners e.g. Educational Psychologist (EP).
Please note that information collected varies according to your interaction with us, i.e. whether you access telephone, face-to-face, video or online services.
Data Collection
What is collected?
To provide helpful psychology and consultancy services to you, your child/young person or organisation, it is important for us to know your situation and what the concerns are that led to support being requested. This data is usually collected from the parent/carer or professional requesting the work through our Client Information for Registration form, Psychological Services & Data Protection form, Pre-Consultation form and Training Booking form. Some individuals may choose to provide additional information in writing or verbally.
For work with children, young people and families, information requested on the Pre-Consultation form can include:
Name and contact details of parents/carers
Name, date of birth and school history of the child
A summary of the child’s current strengths and difficulties
Educational information and attainments
What strategies/interventions have already been tried
Why psychological services have been requested
Family history of learning difficulties and/or other challenges
Information about other factors that may impact on the child’s situation including early development, medical issues, home life, social & emotional skills, mental health and behaviour
We will not request data/information from your child/young person’s school or from other professionals without written permission from you as parents/carers. This permission is given by submitting the consent form. Information is then usually then requested from the SENDCo/Head of Learning Support and/or class or subject teachers. You can outline the best person/s to contact on the form.
For professional services, information requested on the Pre-Consultation form or Training Booking can include:
Name and contact details of lead client
A summary of the current work or problem situation
Why psychological services (e.g. training, supervision, coaching) have been requested and what is hoped to be gained
What strategies / interventions have already been tried
How is it collected?
When you contact Eden Psychology & Consultancy Services Ltd or EdPsychOnline® to request any services, we collect information about you. We collect information when you book a free 15 minute consultation, complete contact forms and/or subscribe to any mailing lists or free online resources. Information may also be collected about you when you visit our website www.edenpsychology.org by using Squarespace and Google Analytics and cookies. When you enter our website, you are required to confirm whether you allow information to be submitted before entering the site.
Contact details are collected from forms completed on and through our website, by corresponding with us by phone, email or letter, or by using publicly available sources (e.g. school/organisation websites).
We do not sell or give your contact details to any third parties for marketing purposes.
Initial-consultation information: When you book an Initial Consultation, you are asked to provide some details about yourself. The details collected are your name, phone number, email address and date of birth. You can also add additional notes.
Consultation, coaching/mentoring and supervision notes: Brief notes summarising the discussion and agreed actions will be taken by the practitioner.
Assessment and therapeutic intervention session notes: Detailed notes will be taken by the practitioner during and following assessments and intervention sessions.
Information from other professionals: School or parents/carers may provide additional documents to support the work being carried out with the child/young person e.g. SEN Support Plans, School Attendance data, Education Health and Care Plans, reports by other health professionals etc.
Information when accessing free resources: When you sign up for free resources and updates, MailChimp is used for delivering the materials and storing your information. Only your first name and email address are collected. You can update your email preferences at all times by following the link at the end of every email.
Why is it collected?
We collect your data to:
Provide helpful and appropriate psychology and consultancy services to you.
Gain a holistic picture of the context, the support needed and who is involved.
To communicate with you so that we can arrange appointments, discuss your concerns and arrange appropriate next steps.
To explore whether there are any factors which may be contributing towards the current situation or which may affect the progress of the work.
To prepare relevant and appropriate assessments, consultation, intervention or training for you.
Data Storage
Where do we keep the data/information?
Data received by post is scanned and stored electronically. All paper copies are shredded. Data is password-protected and may initially be stored in a secure contact database (Microsoft Outlook 365 and Excel spreadsheet) before being uploaded to Cloud systems called WriteUpp and OneDrive for storage.
When data is received by email, attachments will be password-protected and saved in the client’s electronic file. The email will be stored until the completion of the work where the thread will be saved to the client’s electronic file to support tracking of the work and then deleted from the email inbox. All clients are advised to send personal data password protected or by using an encrypted file transfer service.
Electronic information is stored on Cloud systems called WriteUpp and OneDrive. Video Interaction Guidance footage is kept for the purpose of the Shared Review cycle process and is stored electronically on an encrypted iPad. Video content is transferred via OneDrive before being saved on the Cloud. Both WriteUpp and OneDrive usage complies with GDPR.
Working documents are stored on a PC at the working base of the practitioner. The PC is password-protected and each document is individually password-protected with a unique client ID number.
All children/young people that are issued a consent form are recorded on a password-protected master database (Excel spreadsheet) and given a unique reference number.
For Assessment work: Paper records will be filed and kept in a locked filing box/cabinet until all information is converted into an electronic format whereby all paper copies are shredded.
When client paper files are being used/worked on they will be locked in a filing box/cabinet and these files will be shredded at the completion of the work.
When the information is carried to conduct an assessment, the paper file will be kept in a travel bag. This bag will not be left overnight in a vehicle. If left out of sight in a vehicle for a short period during the day, the car will be locked secure. During school visits, we will keep the paper file on our person, or have it locked in a room.
The final report will provide a detailed summary of our involvement. Once a report has been completed, any handwritten notes will be securely destroyed by using a shredder. Paper record forms, writing samples and other assessment materials may be kept for up to two months in case questions are raised about the process of the assessment. They will then be securely destroyed by shredding. A copy will be sent to the school (if the school has purchased the service) and to the parents / carers.
How long do we keep the information?
Retention of child/young person (CYP) records: Eden Psychology and Consultancy Services Ltd will keep records and related information in the CYP electronic folder for a period of six years. This is so that a record of the report remains if parents/carers lose the copy that was sent to them. Also, the report may be referred to, if the pupil is reassessed in the future. We will then delete the CYP electronic folder, related documentation, and remove them from the CYP master database unless we continue to be directly involved with the child/young person and there are strong reasons for retaining historical data, e.g. to track strategies and interventions over time or legal cases. Please note it is the parents’ responsibility to retain copies of the report, because we will only retain the data for six years.
Retention of adult records: If a practitioner works with a client who is aged 18 years or over, their records will be kept for up to three years. In the third year following the work, Eden Psychology and Consultancy Services Ltd will delete the clients electronic folder, related documentation, and remove them from the client master database.
Data Sharing
Supervision: As part of ethical practice, practitioner psychologists are required to seek regular consultation with another psychological therapist who is qualified in this process and may discuss aspects of their work concerning you/your child. This is to ensure that they are able to work to their best ability and offer an ethical service that is helpful to you. The consultation process is protected by confidentiality and the consultant will not know you personally or professionally. Supervision takes place verbally and you may be referred to by your first name or, more likely, by a pseudonym. This process is to ensure professional development.
Who do we send the information to?
Where parents/carers have agreed for us to contact the child/young person’s school, or if the school have commissioned the report, the date of the appointment will be arranged directly between us and the school, with the parent/carer being informed of this date through our communication with them. Alternatively, parents may arrange a date with us and then check with school to ensure it is a mutually convenient date.
School staff may be invited to join a feedback meeting with parents/carers where the assessment is discussed, with parent/carer permission.
Assessment reports are typically only sent to the parents/carers, unless the school has commissioned (i.e. paid for) the assessment, in which case a copy will also be sent to the school, using a password protection.
Reports will be sent out electronically by email to the pupil’s parents/carers. If the parents/carers are happy to share the report, it is their responsibility to forward it to the child/young person’s school and any other relevant professionals.
All reports will be in ‘read only’ format so no changes may be made. They will also be sent password-protected.
Will we send emails and text messages to you?
We will only contact you in response to a request for psychological services that has been initiated either by you or the school. This would usually include emails or phone calls to discuss your current concerns and arrange appointments and may include text messages of appointment reminders. We may also email invoice/payment details to you and the assessment report.
Consent
Consent: Informed consent has to be provided before an Eden Psychology & Consultancy Services Ltd practitioner or Associate practitioner will work with an individual, family or team. For children and young people, the parents/carers must sign a consent form (issued by Eden Psychology & Consultancy Services Ltd) before the practitioner can work with the child/young person. Consent is managed through the WriteUpp system and stored in the electronic client folder. If, for any reason, a paper copy was used, this will be scanned in and the paper copy shredded. All children/young people that are issued a consent form are recorded on the master database (Excel spreadsheet) and given a unique reference number. This password-protected spreadsheet includes: first name, last name, date of birth, first language, gender, ethnicity, school, year group, parent/carer name, parent/carer postal address, parent/carer phone number, parent/carer email address.
Gillick Competence: Is a term used in medical law to decide whether a child (under 16 years of age) is able to consent to his or her own medical treatment without the need for parental permission or knowledge. If the practitioner decides that a child/young person under the age of 16 is Gillick Competent, they can provide support without first requiring parent/carer consent.
Withdrawal of Consent: An individual or parent/carer may withdraw consent for involvement at any time. If consent is withdrawn the individual or child/young person’s electronic folder will be deleted, including any documents related to them, and they will be deleted from the master database (Excel spreadsheet). If the school has discussed concerns related to a child/young person, this will be kept in the school file (if the school is the client) as a record of the conversation between the practitioner and School Contact.
Confidentiality
All work undertaken by Eden Psychology & Consultancy Services Ltd and under its trading name EdPsychOnline® is confidential. Information is only shared with the specific consent of the individual or child/young person’s parent/carer.
If disclosure of information is deemed necessary, practitioners will aim to obtain specific informed consent from their clients, making the consequences of disclosure as clear and unbiased as possible. There are a number of circumstances where this might not be possible or may not apply: for example where the health, safety, security or welfare of the client or someone else may otherwise be put at risk; and if there are legal or safeguarding responsibilities.
Further information regarding confidentiality can be found in The British Psychological Society, Practice Guidelines, August (2017).
Your Rights
You have the following rights:
To be informed what information is collected and how it is stored.
To see the information we hold about you. Please contact Eden Psychology & Consultancy Services Ltd directly to request access via a subject access request (SAR). We may require additional verification that you are who you say you are to process this request. Please make such a request in writing or by email to us. Please provide the following information: your name, address, telephone number, email address and details of the information you require.
To rectify any inaccurate or incomplete personal information.
To withdraw consent to us using your personal information.
To request your personal information be erased (although if the information is needed for us to practice lawfully and ethically we can decline). Restrictions will apply when disclosure would place you/the clients or others at risk of serious harm or if we consider that providing the information will violate your vital interests.
Client access to records will be restricted to information about themselves, or their child/young person where they are the parent/carer.
Data Breaches
If a data breach occurs, and the breach is deemed to be a high risk for the rights and freedoms of the data subject (you/your child), the Information Commissioners Office (ICO) and all affected clients will be notified within 72 hours. The nature of the breach will be explained along with the steps we are taking to deal with it.
Client agreement
When an assessment or consultation is requested, you will be asked to read and sign our Psychological Services & Data Protection Consent form. That document describes the work that we will undertake and, by signing the document, you enter into a contract with us to do the work. We will process all personal data that you share with us (for the purpose of completing an assessment or consultation) lawfully, fairly and in a transparent manner. It will be necessary for us to process your personal data in order to fulfil the contract with you.
A printed copy of the privacy policy can be requested. You will be sent a copy of your signed consent form. An agreed plan of action will be sent to be signed by you and Eden Psychology & Consultancy Services Ltd before work starts. This is to acknowledge that both parties agree on the nature of the work.
Where you have provided explicit consent for us to use your data, you have a right to withdraw this consent at any time.
If you wish to use a different service provider e.g. Educational Psychologist, you have a right to have the data transferred to them.