An Acquired Brain Injury (ABI) is an injury caused to the brain after birth. There are many possible causes, these are classed as:

-traumatic injury for example due to a fall or a road accident

-or a non-traumatic injury for example due to infection, tumour and stroke.

ABI can affect many areas of a person's functionning including: memory and thought processes, physical ability, speech/language, swallowing, physical ability, psychological functioning and/or behaviour. Impairments are not always visible so it can result in a hidden disability.

I am registered data processing officer with the Information Commissioner’s Office (ICO) I operate robust systems to protect data I hold about clients, which meet GDPR compliance. Upon giving written consent for treatment, you will be provided with written terms, conditions and copies of my policies to read and sign.

I have enhanced clearance from the Disclosure and Barring Service (DBS) and subscribe to their update service, allowing instant information about my DBS status.

Helen Price is a Sole trader, since November 2018

Helen Price is a fully qualified Speech and Language Therapist registered with HCPC, RCSLT and ASTLTIP. She holds an up to date Disclosure and Barring Service (DBS) certificate and is a registered as a data holder with ICO.

Services offered and Pricing:

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Initial needs phone consultation: Free

Initial Assessment; includes up to 90 minutes face to face consultation, preparation time, information gathering, formal and informal assessments as appropriate, written report £160

Hourly Rate: £80 / hour to cover:

Direct therapy

Liaison with other professionals

Letters

Programmes

Attendance at meetings

Telephone calls

Therapy sessions

30 minutes £40

45 minutes £60

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All fees are discussed and agreed prior to the start of therapy.

Fees are subject to annual review.

Payments can be made by bank transfer, cheque or cash

A printed receipt can be provided on request.

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Half or full day sessions at schools / nurseries/ care homes for multiple clients: cost on request

Training packages: price on request

Travel costs:

Travel costs from the therapist’s base are charged at 45 pence per mile plus a charge for time; charges for time will then be made in increments of 15 minutes at £10.00 per 15 minutes.

Travel costs can be shared if there are multiple clients in a location.

Payment:

You will receive an invoice for payment which is be payable within 14 days of receipt of the invoice. Payments can be made by bank transfer, cash or cheque payable to Helen Price

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Cancellation of Appointments:

There is no charge for sessions cancelled with 24 hours notice (or within 24 hours if a valid reason given such as illness).

If more than two sessions in a row are cancelled or missed, therapy may be put on hold until circumstances allow for regular attendance.

If the therapist is unable to attend an appointment, the maximum possible notice will be given and the appointment will be rescheduled.

Missed Appointments

Where insufficient notification prior to the therapist starting her journey is given for cancellation, you will be charged, in full at the standard therapy session rate.

If a child’s therapy session is scheduled to take place at nursery or school, it is the parents’ responsibility to inform the therapist directly if their child is not at nursery or school that day.

Termination of Therapy

It is within the therapist’s rights to terminate therapy with 24 hours notice.

It is within the rights of the client to terminate therapy with 24 hours notice.

Frequency of Sessions:

It may be clinically important to continue initial assessment over more than one session. Any further assessment sessions will be charged at the standard rate, dependent on the level of additional assessment required.

Following assessment, the need for further therapy/advice will then be discussed and agreed with the client and or their carers.

Sessions are offered weekly, fortnightly, monthly as appropriate and depending on the needs of the client.

A specific number of therapy sessions will be discussed agreed between the therapist and parents/carers. A mutual review of arrangements will take place at the end of that block of sessions.

A brief update report will be provided after each block of sessions.

Decisions about Discharge

Following assessment and/or therapy sessions the recommendation may be to discharge the client from the therapist’s care. This decision will be fully discussed with the client’s parents/carers beforehand. A report will provided when the client has been discharged.

Access to NHS Therapy

All clients are eligible for Speech and Language Therapy within their local NHS team.

Clients who are currently receiving therapy from an NHS therapist or are on the waiting list must inform the independent therapist.

The NHS therapist should also be informed of any independent therapist involvement to ensure effective liaison.

Consent for Liaison and Distribution of Reports

Written consent for cross professional liaison will be sought from client/parents/ carers who have the right to decline consent for contact with other professionals. Written consent will be gained to share documentation with parents/carers via email, who have the right to decline consent for this.

Liaison, reports or advice from the independent therapist will only be distributed to other relevant professionals (e.g. school or GP) with the written consent of the client’s parents/carers.

Privacy Policy Statement for Helen Price Therapy

When you use Helen Price Therapy you trust me with your information. This privacy policy is meant to help you understand what data I collect, why I collect it, and what I do with it. I have tried to make it as simple as possible but if you have any questions please contact me.

Helen Price assumes the function of data controller and supervises the compliance with General Data Protection Regulation (GDPR) within the business.

1. Information I collect 2. Where I get my information 3. How I use the information I collect 4. Information I share 5. How and when consent is obtained 6. How I protect your data 7. Protecting your rights to data 8. Security of your personal data

1 Information we collect

Helen Price Therapy holds personal data as part of conducting a professional service. The data follows under the following headings: healthcare records, educational records, clinical records, general administrative records, and financial records.

1.1 Healthcare 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 a high quality 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.

For child services: • Parent/guardian details • Description of family • Educational placements. • Pre- and post-natal history: This can include information relating to mother’s pregnancy, and child’s birth. • Developmental data: developmental milestones, feeding history, audiology history. • Medical details: such as any relevant illnesses, medications, and relevant family history. Reports from other relevant allied health professionals such as: Audiology, Psychology, CAMHS (Child & Adolescent Mental Health Services), Occupational therapy, Physiotherapy, Ophthalmology.

For adult services: • Employment/vocational history • Mental health

1.2 Educational records

Relevant Individual Educational Plans (IEPs), progress notes from educational staff and school reports may be held.

1.3 Clinical records

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. Audio and video files may also be collected and stored.

1.4 General administrative records

Helen Price Therapy may hold information regarding attendance reports and accident report forms.

1.5 Financial records

A financial record pertains to all financial information concerning the practice, e.g.

invoices, receipts, information for Revenue. Helen Price Therapy may hold data in relation to: on-line purchasing history, card payments, bank details, receipts and invoices. Information will include name of bill payer, client name, address and record of invoices and payments made.

2 Where I get my information

Personal data will be provided by the client, or in the case of a child (under 16 years), their parent(s)/guardian(s). 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 schools, medical professionals and allied health professionals, with prior consent from the client/parent(s)/guardian(s).

3 How I use the information that I collect

I use the information I collect to provide assessment and therapy as per the relevant professional guidelines, as well as to maintain the general running of the business, such as keeping our accounts and updating you of any changes in policies or fees.

Information may also be used for research purposes, with the written consent of the client or parent/guardian.

3.1 Data retention periods

The retention periods are the suggested time periods for which the records should be held based on the organisation’s needs, legal and/or fiscal precedence or historical purposes. Following the retention deadline, all data will be destroyed under confidential means.

3.2 Client Records

3.2.1 Clinical Records Helen Price Therapy keeps both physical and electronic records of clinical data in order to provide a service.

• The preferred format for clinical data is electronic. • Clinical data for adult clients (over the age of 18 years) is deleted/confidentially destroyed after 8 years from last invoiced session. (Usually post discharge).

• For children clinical records will be kept until a child’s 25th birthday or if the client was 17 at the conclusion of the treatment, until their 26th birthday.

• All data must be reviewed prior to destruction taking into account any serious incident retentions. This includes medical illustration records such as X-rays and scans as well as video and other formats.

• Clinical data used for research purposes, may be kept for longer than the periods above. • 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. (Recordings may be kept for longer if blocks of therapy may occur over a length of time. Permission for this will be sought from the client or parent/guardian).

3.2.2 Financial Records Helen Price Therapy keeps electronic/paper 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.

3.2.3 Contact Data Contact Data is kept for 6 years to allow processing of Financial Data if required. (This may be retained for longer for safety, legal request, or child protection reasons.)

3.3 Exceptions

If under investigation or if litigation is likely, files must be held in original form indefinitely, otherwise files are held for the minimum periods set out above.

4 Information I share

I do not share personal information with companies, organisations and individuals outside Helen Price Therapy unless one of the following circumstances apply:

4.1 With your consent:

I will only share your Personal Identifying Information (PII) to third parties when I have express written permission by letter or email to do so. I require opt-in consent for the sharing of any sensitive information.

Third parties may include: hospitals, GPs, other allied health professionals, educational facilities.

4.2 For legal reasons:

I will share personal information with companies or organisations outside of Helen Price Therapy if disclosure of the information is reasonably necessary to: • Meet any applicable law, regulation, legal process or enforceable governmental request.  • Meet the requirements of the Children First Act 2015.  •To protect against harm to the rights, property or safely of Helen Price Therapy, our service users or the public as required or permitted by law.

4.3 To meet financial requirements:

Helen Price Therapy also is required to share Financial data with a book keeper in order to comply with local tax laws.

5 How and when I obtain consent

Prior to initial assessment or consultation, a link to the data protection policy on my website will be provided to clients along with a client contact and consent form which 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 Helen Price Therapy.

6 How I protect your data

In accordance with the General Data Protection Regulation (GDPR), I will endeavour to protect your personal data in a number of ways:

6.1 By limiting the data that I collect in the first instance

All data I collect will be collected solely for the purposes set out at 1 above and will be collected for specified, explicit and legitimate purposes. The data will not be processed any further in a manner that is incompatible with those purposes save in the special circumstances referred to in section 5.1. Furthermore, all data I collect will be adequate, relevant and limited to what is necessary in relation to the purposes for which it is collected which include, inter alia, the assessment, diagnosis and treatment of speech, language and communication disorders.

6.2 By transmitting the data in certain specified circumstances only

Data will only be shared and transmitted, be it on paper or electronically, only as is required, and as set out in section 3.

6.3 By keeping only the data that is required

I shall only retain data when it is required and will protect it by limiting its accessibility to any other third parties.

6.4 By disposing of/destroying the data once the individual has ceased receiving treatment

Data will be disposed/destroyed within 8 years of the completion of this treatment for adults and when a child client reaches the ages specified in section 3.2.1 apart from the special categories of personal data as set out at 1.1 above. Where data is required to be held us for longer than the period specified in 3.2.1, I will put in place appropriate technical and organisational measures to ensure a level of security appropriate to the risk. These may include measures such as the encryption of electronic devices, pseudonymisation of personal data, and/or safe and secure storage facilities for paper/electronic records.

6.5 By retaining the data for only as long as is required

which in this case is the length specified in 3.2.1 except for circumstances in which retention of data is required in circumstances set out at part 1.1 above or in certain specific circumstances as set out at Article 23(1) of the GDPR.

6.6 By destroying the data securely and confidentially after the period of retention has elapsed.

This could include the use of confidential shredding facilities or, if requested by the individual, the return of personal records to the individual.

6.7 By ensuring that any personal data collected and retained is both accurate and up-to-date.

7 Protecting your Rights to Data

7.1 Adult clients

Adults have the right to request data held on them as per article 15 of GDPR. A request must be made in writing. Further information regarding accessing your personal data are available in the document ‘Rights of Individuals under the General Data Protection Regulation’, downloadable from: www.gdprandyou.ie

7.2 Children

For children under the age of 16, data access requests are made by their guardians. When a child turns 16, then they may make a request for their personal data. However, this is subject to adherence with the Children First Act.

8 Security

Helen Price Therapy, as with most providers of healthcare services is aware of the need for privacy. As such, I aim to practice privacy by design as a default approach, and only obtain and retain the information needed to provide you with the best possible service.

All persons working in, and with Helen Price Therapy in a professional capacity are briefed on the proper management, storage and safekeeping of data.

All data used by Helen Price Therapy, including personal data may be retained in any of the following formats: 1. Electronic Data 2. Physical Files

The type of format for storing the data is decided based on the format the data exists in.

Where applicable, Helen Price Therapy may convert physical files to electronic records to allow us to provide a better service to clients.

8.1 Data Security

Helen Price therapy understands that the personal data used in order to provide a service belongs to the individuals involved. The following outlines the steps which Helen Price Therapy uses to ensure that the data is kept safe.

8.1.1 Electronic Data

All electronic data is contained in the following systems: Gmail, and folders in an online encrypted cloud store.

8.1.2 Physical Files

All physical data is located at my home address. - Only Helen Price has access to these records. - These records ARE kept in a container secured with a lock and key.

8.2 Security Policy

8.2.1 Helen Price Therapy understands that requirements for electronic and physical storage may change with time and the state of the art. As such, the data controller in Helen Price Therapy reviews the electronic and physical storage options available to Helen Price Therapy every year.

8.2.2 Helen Price uses strategies for good data hygiene including, not limited to:  Awareness of client conversations in unsecure locations.  Enabling auto-lock on devices when leaving them unattended, even within my home address.  Use of non-identifiable note taking options. (initials, not names).  The awareness of best practice procedure should a possible data breach occur, either through malicious (theft) or accident (loss) of devices or physical files.

Date of document: 11/11/2018 Review Date: 11/11/2019