At Vox Humana, we are strongly committed to protecting your privacy and every reasonable effort is taken to ensure that your information is kept secure and intact. This policy describes how Vox Humana collects and uses personal information about the people who visit our website and give us their data over the phone, face-to-face, and in writing. This policy also states how and why we use data, how we store it and how individual personal preferences can be amended.
The terms of this policy may change, so please check it from time to time.
By using our website, you are accepting and consenting to the practices described in this policy. If you have any queries about this policy please contact:
- Your personal information is only used for the purpose for which we collect it and only information that we need is collected.
- Your personal information is only seen by those who need it to do their jobs.
- We will only disclose data when we have your consent, or where we are obliged to disclose personal data by law, or as expressly permitted under the GDPR (through contract; legal obligation; vital interests; public task; or legitimate interests).
- We will keep your information up to date. Inaccurate or misleading data will be corrected as soon as possible.
- Personal information is retained only for as long as it is required for the purpose collected.
- Your information will be protected from unauthorised or accidental disclosure and processed in an appropriate manner to maintain its integrity and confidentiality.
- We will provide you with a copy of your personal information on request (please see below for information on access rights and requests).
These principles apply whether we hold your information on paper or in electronic form.
How do we collect information?
We obtain personal information from you when you enquire about our activities, register with us, send or receive an email, ask a question or otherwise provide us with personal information.
We will only ever collect the information that we need.
We also gather general information about the use of our website, such as which pages users visit most often and which services are of most interest.
What information do we collect?
Vox Humana holds personal data as part of conducting a professional service. The data is held under the following headings: healthcare records, clinical records and financial records.
A healthcare record refers to all information collected, processed and held both in manual and electronic formats pertaining to the service user and their care. Speech and language problems can be complex, and a wide range of information may be collected in order to best meet the needs of the client, and to maintain a high-quality service which meets best practice requirements. In order to provide this service, a range of information may be collected.
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.
- Employment/vocational history
- Mental health
Specific data in relation to communication skills may be collected and held, such as assessment forms, reports, case notes, e-mails, text messages and transcripts of phone conversations. Audio and video files may also be collected and stored.
We collect special categories of personal data only if we are permitted to do so by data protection law, and we have additional measures in place to protect this data.
A financial record pertains to all financial information concerning the practice, e.g. invoices, receipts, information for Revenue. Vox Humana may hold data in relation to: payments, receipts and invoices. Information will include name of bill payer, client name, address and record of invoices and payments made.
Where we get our information
Personal data will be provided by the client. This information will be collected as part of a case history form prior to, or on the date of first contact.
Information may also be provided directly from relevant third parties such as medical professionals and allied health professionals.
Why do we collect this information and how do we use it?
We collect this information for the purposes of providing assessment and therapy as per the relevant professional guidelines, as well as to maintain the general running of the business, communicating effectively and appropriately with our clients.
The lawful basis for which we process your information is:
- your consent;
- processing is necessary for the performance of a contract to which you are a party. If you fail to provide this information we may be unable to perform the contract;
- processing is necessary for compliance with our legal obligations,
- processing is necessary to protect your interests or that of another person;
- processing is necessary for the performance of a task carried out in the public interest;
- processing is necessary for the purpose of the legitimate interest pursued by us, except where your rights as a data subject override our legitimate interest. The legitimate interest we rely upon is subject to an assessment based on the specific context and circumstances.
- to provide you with information that you have indicated an interest in, for example specific speech and language therapies;
- we may use this information to personalise the way our website is presented when users visit it, to make improvements to our website and to ensure we provide the best service for users;
- for administrative purposes.
Do we share your information with anybody else?
We do not share your personal information with anybody else, unless one of the following circumstances apply:
With your consent
We will only share your Personal Identifying Information (PII) to third parties when we have express written permission by letter or email to do so. We require opt-in consent for the sharing of any sensitive information.
Third parties may include: hospitals, GPs and other allied health professionals.
For legal reasons:
We will share personal information with companies or organisations outside of Vox Humana if disclosure of the information is reasonably necessary to:
- Meet any applicable law, regulation, legal process or enforceable governmental request.
- To protect against harm to the rights, property or safely of (name of business), our service users or the public as required or permitted by law.
We do not sell personal details to other third parties.
How and when we obtain consent
Prior to initial assessment or consultation, a copy of the data protection policy will be provided to clients along with a client contract. A consent form will need to be signed by the client prior to commencing the service. Copies of the signed consent forms and client contract will be given to both parties.
Should a client wish to withdraw their consent for data to be processed, they can do so by contacting firstname.lastname@example.org
Storing and protecting your information
We recognise the concerns that many people have about giving personal information online.
We place great importance on the security of all personally identifiable information associated with our clients. We have security measures in place to protect against the loss, misuse and alteration or destruction of personal data under our control. Information is stored by us on computers located in the UK. Our client database (Cliniko) is protected by encryption.
Data Retention Periods
We will keep your information only for as long as is required to provide you with the services or information you have required, to administer your relationship with us, to comply with the law and tax accounting rules, or to ensure that we do not communicate with people who have asked us not to. We keep only data that is required.
When your information is no longer required, we will always dispose of it securely.
Vox Humana keeps electronic records of clinical data, in order to provide a service.
- The preferred format for clinical data is electronic.
- Clinical data is deleted/confidentially destroyed after 7 years from last invoiced session. (Usually post discharge – in accordance with RCSLT guidelines).
- Video records/ voice recordings relating to client care/videoconferencing records 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.
Vox Humana keeps electronic records of financial data from those who use our services.
Section 886 of the Direct Tax Acts states that the Revenue Commissioners require records to be retained for a minimum period of six years after the completion of the transactions, acts or operations to which they relate. These requirements apply to manual and electronic records equally.
- Financial Data is kept for 6 years to adhere to Revenue guidelines.
- Financial Data (including non-payment of bills) can be given to Revenue at Revenue’s request.
Contact Data is kept for 6 years to allow processing of Financial Data if required.
Payment Card Information
Vox Humana does not store any sensitive payment card data in our systems.
You have a right to ask us to confirm whether we are processing information about you, and to request access to this information (‘right of access’). We will ask you for proof of your identity before we can act upon your request. To obtain a copy of the personal information we hold about you, please contact us by email at email@example.com
You may ask us, or we may ask you, to rectify information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate or complete information which is incomplete (‘right to rectification’).
You have a right to obtain your personal data from us and reuse it for your own purposes, perhaps for another service, without hindering the usability of the data (‘right of portability’).
You have a right to seek the erasure of your data (often referred to as the ‘right to be forgotten’). You may wish to exercise this right for any reason, for example where it is no longer necessary for us to continue holding or processing your personal data you may withdraw your consent. You should note that we are entitled to and reserve the right to retain your data for statistical purposes. This right is not absolute, as we may need to continue processing this information, for example, to comply with our legal obligations, or for reasons of public interest.
You have a right to ask us to restrict our processing of your information (‘right to restriction’).
If you would like to exercise any of your rights above, please contact firstname.lastname@example.org We will act in accordance with your instructions as soon as reasonably possible and there will be no charge.
You have a right to report any of your concerns about our use of your data to the Information Commissioner’s Office. You may do so by calling their helpline at 0303 123 1113. Website: www.ico.org.uk
Date of document: 31 July 2018
Review Date: 31 July 2019