Plum Tree Psychology

Independent Educational Psychologist

Privacy Policy

Introduction

I aim to be as clear as possible about how and why I use information about you/your child, so that you can be confident that your privacy is protected. This policy describes the information that I collect and how I manage your information when you use my services. This information includes personal information (data) as defined in the General Data Protection Regulation (GDPR) 2016 and the subsequent UK Data Protection Bill, 2018. I use the information I collect in accordance with all laws concerning the protection of personal data, including the Data Protection Act 1998 and the GDPR 2016. As per these laws, I am the data controller for the information that you give to me.

The GDPR requires that I identify the legal basis upon which I process your personal data. I shall provide psychological services and all associated activities on the basis of:

  1. My contract with you
  2. My legitimate interest to hold and process your personal data.

What is meant by ‘The contract’?

When an assessment or consultation is requested, the client is asked to read and sign my terms and conditions. That document describes the work that I will undertake and, by signing the document, you enter into a contract with me to do the work. I will process all personal data that you share with me (for the purpose of completing an assessment or consultation) lawfully, fairly and in a transparent manner. It will be necessary for me to process your personal data in order to fulfil the contract with you.

What is meant by ‘Legitimate Interest’?

The reason that I need to process your personal data is to provide psychological services to you/your child. Inevitably, educational psychology assessments/consultations involve the processing of special category data, including information, for example, about your child’s health, cognitive functioning, social and emotional issues and family history. I have a legitimate interest to collect such personal data for the purpose of forming a well-informed professional opinion. I will only collect information from you that is relevant for the process of providing the psychological services that you have requested.

1. Why do I need to collect your personal data?

In order to carry out an effective assessment or consultation, I need to collect information about you and / or your child so that I may:

  • Communicate with you in a personal way. The legal basis for this is a legitimate interest.
  • Deliver services to you/your child, for example by preparing a relevant assessment and providing well informed psychological advice for your child. The legal basis for this is the contract with you.

2. What personal information do I collect and when do I collect it?

To provide helpful psychological services to you/your child, it is important for me to know your child’s situation and what the concerns are, that led to psychological support being requested. This data is usually collected by the parents completing a Parental Consent and Pre-assessment questionnaire. Some parents may choose to provide additional information in writing or verbally. Information requested on the consent form includes:

  • Name and contact details of parents
  • Name, date of birth and school of the child
  • A summary of the child’s current strengths and difficulties
  • What strategies / interventions have already been tried with the pupil
  • Why psychological services have been requested
  • Information about other factors that may impact on the child’s situation including family history of learning difficulties and/or challenges, early development, medical issues, home life, social & emotional skills and behavioural observations.

In order to gain a holistic picture of the child it is also helpful to receive information from the child’s school and other professionals that have been involved. This information includes:

  • Name, date of birth and school of the child
  • A summary of the child’s current strengths and difficulties
  • What strategies / interventions have already been tried with the pupil
  • Why psychological services have been requested
  • Educational information and attainments
  • Social, emotional and behavioural observations
  • For pupils approaching GCSEs or other public exams the school may need to send a document called Form 8, if it is thought that the pupil may need Access Arrangements (e.g. additional time) as managed by the Joint Council for Qualifications (JCQ).

No data will be requested from school or other professionals without parental consent.

3. How do I use the information that I collect?

The information collected is used in the following ways:

  • To communicate with you so that I can arrange appointments with you, discuss your concerns and arrange an appropriate course of action.
  • To prepare a relevant assessment / consultation for your child. It will help me to decide what assessments to use and what approaches I should take with the child. Background information about the child’s situation is important so that I am aware if the child has experienced trauma or other issues that may affect their emotional well-being or ability to learn. It is helpful for me to see previous reports from other professionals, in order to put my work in context with the child’s development over time.
  • Where relevant, information provided by others (e.g. parents, school, health professionals etc.) will be included with the data I collect during assessment and I will write a report summarising pertinent information.

4. Where do I keep the information?

  • Data is usually received via Power Diary, which is customer management software. Some information may be provided by email. Power Diary is GDPR compliant and is specifically designed to help psychologists and health professionals to manage their client records and communication confidentially and effectively. Any paper records will be filed and kept in a locked filing cabinet.
  • When the information is needed to conduct an assessment, my laptop and paper files will be kept in a travel bag. This bag will not be left overnight in a vehicle.
  • Should your personal data that I control be lost, stolen or otherwise breached, where this constitutes a high risk to your rights and freedoms, I will contact you without delay. I will explain to you the nature of the breach and the steps I am taking to deal with it.

5. How long do I keep the information?

  • The report will provide a detailed summary of my involvement. Once a report has been completed, any handwritten notes will be securely destroyed. Paper record forms, writing samples and other assessment materials may be kept for up to three months in case questions are raised about the process of the assessment. They will then be securely destroyed.
  • All electronic files, including parental consent, my psychological reports and communication records on Power Diary will be retained for a period of six years. This is so that I have a record of my interaction with a client if they contact me in future. I am also able to provide a copy of my psychological report, if parents lose the copy that was sent to them. Also, the report may be referred to if the pupil is reassessed in the future. After a period of six years, all remaining records will be securely destroyed, unless I continue to be directly involved with the case and there are strong reasons for retaining historical data. E.g. to track strategies and interventions over time.
  • Please note it is the parents’ responsibility to keep a copy of the report, because I will only retain the data for six years.

6. Who do I send the information to?

  • Where parents have agreed for the psychologist to contact the pupil’s school, I will contact the school to arrange appointments. School staff are typically invited to join a feedback meeting where the assessment is discussed, again with parental permission.
  • Assessment reports are typically only sent to the parents, unless the school has commissioned (i.e. paid for) the assessment, in which case a copy will also be sent to the school.
  • Reports will be sent out electronically via an email generated by Power Diary to the pupil’s parents. If the parents are happy to share the report, it is their responsibility to forward it to the child’s school and any other relevant professionals.
  • All reports will be in ‘read only’ PDF format so no changes may be made. They will also be password protected. The password will be sent separately, usually by text, in case either my, or the parents’, email accounts have been compromised. It is the parent’s responsibility to retain the password for future reference. Parents can choose for the report not to be password protected if they prefer.

7. Will I send emails and text messages to you?

  • I 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. I will also email an invoice to you and the assessment reports.

8. What happens to your data if I were to die?

  • In the event of my unexpected death all pupil data will be confidentially destroyed by the executors of my will.

9. Your rights

  • As I process your personal data, you have certain rights. These are a right of access, a right of rectification, a right of erasure and a right to restrict processing.
  • You may request a copy of your data at any time. Please make such a request in writing or by email to me, Plum Hutton, the Data Protection Officer. Please provide the following information: your name, address, telephone number, email address and details of the information you require.
  • If you believe any of the personal data I hold on you/your child is inaccurate or incomplete, please contact me directly and any necessary corrections to your data will be made without undue delay.
  • If you believe I should erase your data, please contact me, Plum Hutton.
  • If you wish me to stop storing or using your data, please contact me.
  • Where you have provided explicit consent for me to use your data, you have a right to withdraw this consent at any time.

If your questions are not fully answered by this policy, please contact me directly in my role as Data Protection Officer for Plum Tree Psychology. If you are not satisfied with the answers I provide, you may contact the Information Commissioner’s Office (ICO) https://ico.org.uk.