Privacy & Data Protection Policy
Managing Minds Ltd (MM) cares about protecting the privacy of its clients. This Privacy and Data Protection Policy explains our views and practices concerning privacy, and how they may relate to a client or a school. This policy sets out the basis on which any personal data we collect from a client or school will be processed by us. Please read the following carefully to understand our views and practices regarding client’s personal data and how we will treat it. For the purpose of the Data Protection Act 1998 (the Act), the data controller is Managing Minds Ltd. ‘We’ refers to Managing Minds, ‘client’ refers to the individual receiving support, ‘MM Practitioner’ refers to the director of MM or a Managing Minds Associate Practitioner.
Managing Minds Ltd is registered with the Information Commissioner’s Office (ICO) www.ico.org.uk
SECTION 1 – INFORMATION WE MAY COLLECT ABOUT A CLIENT We may collect and process the following data about a client:
- Information about a client may come from the parent/carer, social care, school or other agencies. This might be through written means (i.e. consent form, email) or via conversation (i.e. telephone, in person).
- Information collected may include: name, DOB, school name, year group, medical issues, family circumstances, languages spoken at home, other agencies involved, concerns from school/home, disabilities, safeguarding concerns, strengths/hobbies/interests, concerns about social, emotional, behavioural, mental health or wellbeing.
- Working case notes include information on how the client is feeling/thinking/behaving, how they are responding to the sessions, any strategies that are taught, general relevant background on what’s been happening that week for them, etc. Minimal information is recorded and wherever possible, names/identifiable information is not recorded. Some observational notes may be recorded about how the client presents, body language, signs of emotional distress, etc.
SECTION 2 – WHY DO WE COLLECT CLIENT INFORMATION? We use information we receive about a client to inform the work we do with that client and ensure that any approaches we use are suitable and safe, to ensure that any precautions or safeguards can be put in place and to check for any contraindications. The information enables a quicker rapport to be built and can help the MM Practitioner to avoid certain topics that may distress a client. We use the information to ensure we can support every client in the safest, most ethical and effective way possible. We do not pass on this information for any marketing or advertising purpose.
Working case notes help the MM Practitioner recall information between sessions to avoid the client needed to repeat themselves. It also helps the MM Practitioner with the writing of the summary report (see section 7).
Some of the information we collect may be used/shared in certain circumstances (see section 4).
SECTION 3 – CONSENT For a MM Practitioner to work with any client aged under 18 yrs, signed consent from whomever has legal parental responsibility for that young person is required. Specific, additional consent is required for the use of clinical hypnotherapy with a client as indicated by ticking a box on the parent/carer consent form allowing or refusing consent. The consent provided lasts for 12 months after which consent is required again if a client is re-referred.
Consent to work with a MM Practitioner is also obtained from each client. Details about confidentiality, what is recorded and why/how, is all explained to the client in terms appropriate to their level of understanding. If it is age appropriate, the client signs a consent form to confirm this.
SECTION 4 – DISCLOSURE / CONFIDENTIALITY We may disclose information about a client or provided by a client (adult or young person) for the following reasons:
- If the safety, health or wellbeing of a child or vulnerable adult is at risk
- If an illegal activity is disclosed
- If the MM Practitioner or their notes are subpoenaed to court
- If any legislation demands that we share information, i.e. The Children’s Act
SECTION 5 – DATA STORAGE & SECURITY To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. Electronic information containing sensitive or personal details are kept in password protected files and stored on encrypted, password protected memory sticks/laptops. Paper copies of information are stored securely away from the school premises. Client information including consent forms and working case notes are kept for a minimum of 5 years. Client case notes are anonymised wherever possible.
SECTION 6 – SUMMARY REPORTS Summary reports are often provided to schools who commission the work with a client. A summary report may include: name, school, DOB, year group, targets set and progress against these, a brief summary of how the client presented in the session, evaluation feedback given by the client and recommendations. Client’s are informed in advance about these reports and what will be written in them. The purpose of these summary reports is to help schools monitor how effective the work has been and keep a record of interventions a client has been involved in. The summary reports are sent to schools via email in a password protected Word document or hand delivered to the relevant contact person in the school in a sealed envelope. Schools may choose to send these reports to parents/carers. Further information on how each school uses these summary reports would need to be obtained from each individual school. MM advises schools that the summary reports can be used as evidence towards EHC plans or shown to other professionals to support a client, with permission from the client and parent/carer.
SECTION 7 – DOWNLOADS Some files are made available to clients to download from the MM website (www.managingminds.co.uk). Each file is protected by a password which is provided to the client if the MM Practitioner feels the file is relevant to them. Clients are requested NOT to share this password or allow others access to these files for safety and copyright reasons.
Any downloadable documents, files or media made available on the MM website are provided to users at their own risk. While all precautions have been undertaken to ensure only genuine downloads are available users are advised to verify their authenticity using third party anti-virus software or similar applications.
SECTION 9 – YOUR RIGHTS Our site may, from time to time, contain links to and from other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
QUESTIONS AND CONTACT INFORMATION If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact us by email at firstname.lastname@example.org