Privacy, Safety and Terms
KCC LTD
PRIVACY POLICY
1) Who we are
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1.1 Kiki’s Children’s Clinic Ltd (KCC) is a private paediatric therapy practice registered with Companies House No. 8726418. The clinic was established in 1996.
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1.2 KCC delivers private paediatric physiotherapy, occupational therapy and speech and language therapy to babies, children and adolescents at the clinic, their homes or at nurseries and schools. The clinic is owned and directed by Kiki von Eisenhart-Goodwin, Paediatric Physiotherapist, who is registered with the Health and Care Professional Council (HCPC).
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1.3 KCC operates a website at www.kikisclinic.com
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1.4 KCC is committed to protecting the privacy of information provided by clients.
2) Collection of Personal Information
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2.1 Information about your child may be collected via spoken or written information from parents/carers. With parental consent, information may also be collected from other professionals working with your child (such as teachers, nursery staff, childminders, NHS professionals). 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.
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2.2 You may use the KCC 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.
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2.3 You may add comments or queries which might also contain personal information.
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2.4 If your enquiry does not result in your child being seen by KCC then this personal information will be deleted once your enquiry has been dealt with. If your child is subsequently seen by KCC these details may be added to their personal record.
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2.5 The website contains links to other Internet sites which are outside our control and are not covered by this privacy policy. We are not responsible for data which you provide through any such linked websites.
3) Our Use of Personal Information
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3.1 Personal information collected by us via the KCC website, email, telephone or face to face, is stored and used by us for the purpose of delivering your child's physiotherapy, occupational therapy or speech and language therapy.
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3.2 Any sensitive personal details are stored in a secure and confidential system and processed in confidence by the KCC therapists and shall only be used for the purposes of delivering appropriate therapy services to your child.
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3.3 With your consent, information about your child's therapy needs will be shared with other professionals involved in your child's care, when it is in your child's best interests. A record of your consent is kept within your child's case notes.
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3.4 Unless we are required to do so by law, we will not disclose any personal information collected to any person other than as set out above.
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3.5 We do not employ agents to process personal data, for example specialist mailing companies to send out communications.
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3.6 We do not give or sell client details to any third parties.
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4) How we use personal information
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4.1 We use this information:
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To prepare, plan and provide therapy services appropriate for your child's needs;
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To communicate with you via post, email, telephone, mobile messages and SMS in relation to:
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confirming and preparing for appointments
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general communication in-between appointments
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sending you reports and programmes for your child
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copying you into communications with other professionals involved with your child (your child's initials rather than full name will be used in emails)
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- sending you resources
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- sending you invoices and receipts.
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For clinical audit to assess and improve our service. Results of audits are always presented with all client identities removed.
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For management and administration, for example surnames of clients are included in our password protected accounting database.
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4.2 Whenever personal identifiers are not needed for these tasks, if possible, we remove them from the information we use.
5) How we store personal information
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5.1 All information about you, your child and their therapy is stored securely in our systems to ensure that we have a complete record of our service to them.
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5.2 We use a secure electronic cloud-based system called SharePoint which is compliant with general data protection regulations. Prior to being uploaded to this system documents are temporarily stored on a Local server system which is only accessible via a password held by a restricted number of members of the management team.
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5.3 Documents which contain confidential information such as reports and programmes are also individually password protected from the outset.
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5.4 Any paper based confidential information such as assessments are stored securely in accordance with Data Protection Regulations.
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5.5 Videos and photos may be taken of clients with parental consent. These are temporarily stored on an encrypted and password protected tablet. These may then be viewed by the therapist in order to make notes in a client record within 24 hours of the child's appointment. Any videos or photos are either deleted or stored in the child’s electronic records.
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5.6 The minimum amount of confidential information will be taken out of the clinic's office
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base. When your child's information is taken out of the office base it will be kept with the
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therapist or locked in the boot of the Therapist's car (whichever is deemed most secure at
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that time).
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5.7 In accordance with law, all records for clients who have been discharged from KCC will
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be held for 8 years; for those children with ongoing therapy, it will be held securely until
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your child is 25 years old. After this time all records relating to your child will be destroyed.
6) Meeting our professional obligations
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6.1 It is a legal requirement for all Allied Health 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.
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6.2 These standards affect the way in which we process and share information. Specifically: 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.'
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6.3 For further information the full document can be found at: http:/hcpcuk.org/assets/documents/10004EDFStandardsofconduct,performanceandethics.pdf
7) UK Data Protection Law and EU General Data Protection Regulations
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7.1 Data Protection Law lays down wide-ranging rules, backed up by criminal sanctions, for the processing of information about identifiable, living individuals. It also gives individuals certain rights in relation to personal data held about them by others.
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7.2 Kiki von Eisenhart-Goodwin is registered with the Information Commissioner's Office (ICO) as a Data Controller. You can view her ICO registration by visiting: www.ico.org.uk/ESDWebPages/Entry/Z7046100 http://www.ico.org.uk/ESDWebPages/Entry/Z7046100 and please also check: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/ applications/children/
8) Our lawful basis for processing personal information
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8.1 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.
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8.2 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. Physiotherapists, Occupational Therapists and Speech & Language Therapists are legally bound to keep client information confidential, and it is under this condition that we process and store personal information.
9) Our responsibilities
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9.1 We are committed to maintaining the security and confidentiality of your child's record. We actively implement security measures to ensure their information is safe, and audit these regularly.
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9.2 We will not release your personal details to any third party without first seeking your consent unless this is allowed for or required by law.
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9.3 We are constantly working to ensure compliance with current data protection regulation.
10) Your rights
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10.1 Data protection legislation gives you, the parent, various rights. The most important of these are as follows:
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You have the right to a copy of information we hold about your child.
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You have the right to ask for your record to be amended if you believe that it is wrong.
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11) How to access your child's records
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11.1 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.
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11.2 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:
Subject Access Requests
Kiki’s Children’s Clinic Ltd
124 Thurleigh Road
London SW12 8TU, UK
If you have any further questions about how we use your information, please contact
Kiki@kikisclinic.com
Further information about data protection legislation and your rights is available from the
Information Commissioner's Office, or by calling Kiki on 020-7642 0078