Privacy Policy ... looking after and sharing your information

In order for a child/young person to undergo an assessment and intervention Health Horizons Ltd need those with parental responsibility, young people aged over 13 years, and those responsible for commissioning services to understand the privacy arrangements. This is in line with the General Data Protection Regulation (GDPR) which is a regulation in EU law on data protection and privacy for all individuals within the European Union.

What information is to be collected:
Information will be collected (from children, young people, their carers and professionals involved) through direct questioning (face to face or by video conferencing), questionnaires and reviewing previous correspondence and documents. The legal reason for collecting this data will depend on the purpose of the assessment e.g. to understand and benefit the development or mental health of a child/young person, or to advise in care or legal proceedings. Please see the Information Commissioners Office website: www.ico.org.uk. for a further explanation of the legal reasons to collect data. The reason Health Horizons collect data will be satisfied by one of the following legal reasons:

• The individual whom the personal data is about has consented to the processing.
• The processing is necessary for administering justice, or for exercising statutory, governmental, or other public functions.
• The processing is in accordance with the "legitimate interests" condition.

The information collected will be classified as sensitive personal data. Examples include identifying information, mental and physical health history, care history, and information about relationships and important third-party information. The legal reasons for collecting this information are:

• The individual whom the sensitive personal data is about has given explicit consent to the processing.
• The processing is necessary in relation to legal proceedings; for obtaining legal advice; or otherwise for establishing, exercising or defending legal rights.
• The processing is necessary for medical purposes, and is undertaken by a health professional or by someone who is subject to an equivalent duty of confidentiality.

Where the information will be stored:
Clinical notes, correspondence, and questionnaires will be kept in an electronic file (on each director's laptop). The laptop is password protected and will be backed up on an encrypted hard drive. They will also be stored on a shared secure cloud system. Our admin team will have access to these. Some information may also be on a password protected mobile phone. Files, laptop, hard drive and phone will be carried and transferred by vehicle. Records will be kept for seven years following involvement with our service or until the young person is 25 years old, whichever is the latest. After this time, they will be destroyed.

Consent:
Consent must be appropriate to the age and capacity of the individual. Where appropriate one person with parental responsibility and children aged over 13 years old will be asked to provide their consent for an assessment/intervention to take place where appropriate. A summary of the privacy policy will be embedded into the consent form and the children will have a child friendly format. They will be directed to this privacy policy for further information. However please be aware people that are Gillick competent, can give their own consent to involvement with a professional and then parental consent is not required.

Confidentiality:
If you specifically ask Health Horizons Limited to keep some information confidential, then we can discuss how we can achieve this. By law though, some information will need to be shared if we are concerned that someone may come to some harm. Attempts will always be made to find an agreed solution together, as to how the information is shared if this is deemed necessary. This will not be possible in situations deemed as high risk.

Exceptions and other information sharing:

• We advertise through our website, and we ask that when any referrer makes contact with Health Horizons Limited to share personal data on first contact, they read this policy and only send information to us with their consent. We recommend a password protected document.
• Anonymous information can be shared with our clinical supervisors to assist our practice, in line with professional standards.
• In a young person's best interests, some information can also be shared with other agencies and professionals for their wellbeing. For example parents, carers, care staff, teachers, social workers, and other health professionals may need information to meet a young person's needs; to manage risks; and to assess progress and outcomes. As professionals, Health Horizons work as a team around a child or young person as integrated care planning is good practice. In such circumstances information could be shared in person, on the telephone, through letters, or anonymised or password protected emails. When sharing information in this way Health Horizons will endeavour to share our opinion only. The law permitting, Health Horizons will not share anything that people tell us is specifically confidential. If there are any objections and concerns at the outset please let Health Horizons know.

Rights, withdrawal of consent, complaints:
Further information about your rights can be found on the website for the Information Commissioners Office (ICO): www.ico.org.uk. Consent is able to be withdrawn at any time. If you have a complaint about the way your data is managed please let Health Horizons know in the first instance so we can assist on info@healthhorizons.org.uk. However if this is not handled to your satisfaction please also contact the ICO.

Procedures to identify, manage, and report personal data breaches to the Council
The data controller is Dr. Mireille Formosa. The directors in the company are responsible for providing management supervision to all associates that work with us. Any breaches are to be reported to the directors. This information will then be provided to Dr. Mirelle Formosa to liaise with the council about such breaches.

The UK GDPR provides the following rights for individuals:

1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. Rights in relation to automated decision making and profiling.
We will support you to exercise your rights. Any concerns please talk to us, and we will liaise with the necessary parties to advocate for your rights.

Governance - Taking care of you…

Professional Memberships of the Directors

Dr. Nicola Kennelly is a chartered member of the Division of Clinical Psychology and an Associate Fellow of the British Psychological Society (AFBPsS - awarded in recognition of several years experience and contribution to the field of psychology).
The British Psychological Society: 079031

All Clinical Psychologists practicing in England are required to meet standards set by the Health and Care Professions Council in order to safely practice. Dr. Nicola Kennelly is a Registered Practitioner Psychologist with the Health and Care Professions Council.
Health and Care Professions Council: PYL 17346

Dr. Mireille Formosa MD MRCPCH (UK)
All paediatricians practising in England are required to meet the standards set by The General Medical Council (GMC) in order to safely practice. Mireille Formosa is a Registered Doctor with a License to Practice with the General Medical Council. She is also on the Paediatrics Specialist Register and is a trainer recognized by the GMC.
General Medical Council Number: 6117776

In addition, she is also a Member of the Royal College of Paediatrics and Child Health (RCPCH) and the British Association of Community Child Health (BACCH)
RCPCH Membership number 16707
BACCH Membership number 4019

Ms Jill Neame
All Speech and Language Therapists practising in England are required to meet standards set by the Health and Care Professions Council in order to safely practise. Jillian Neame is a Registered Speech and Language Therapist with the Health and Care Professions Council.
Health and Care Professions Council: SL03989

She is also a member of the Royal College of Speech and Language Therapists, Membership Number :RC0004835

Police Check
Dr. Nicola Kennelly has an up to date enhanced certificate to work with children from HM disclosure and barring service (DBS). She is registered with their update service so this status will be continually monitored and maintained.
Disclosure and barring service update service, certificate number 001426058530 (18/11/13)

Dr. Mireille Formosa has an up to date enhanced certificate to work with children from HM disclosure and barring service (DBS).
Disclosure and barring service, certificate number : 001627437167 (23.08.18)

Ms. Jill Neame
Jillian Neame has an up to date enhanced certificate to work with children from HM disclosure and barring service (DBS). She is registered with their update service so this status will be continually monitored and maintained.
Disclosure and barring service update service, certificate number : 001463185433 (17/10/2019)

Data Protection
Health Horizons Limited are registered with the Information Commissioner's Office (ICO) – Reference number is : ZA500944.

Insurance
Health Horizons have public and professional liability insurance.

Care Quality Commission (CQC)
Health Horizons Limited is currently in the process of registering with the CQC.

Annual Training Required
https://freecoursesonline.co.uk/business/data-protection-and-data-security/