Privacy Policy

We need to keep a record of the care we provide to ensure that:

• Professionals involved in your child’s (or your) care have accurate and up-to-date information
• We have all the information necessary for assessing you and/or your child’s needs and providing excellent care
• Your concerns can be properly investigated if you raise a complaint
• Accurate information is available if your child (or yourself):
  • Move to another area
  • Need to use another service
  • See a different healthcare professional.

We have a duty to:

• Maintain full and accurate records of the care we provide
• Ensure that records are confidential, secure and accurate
• Provide a copy at your request that is an accessible format (e.g. in large type if you are partially sighted). This record may include some or all of the following:
  1. Your child’s (and/or your) name, address and date of birth.
  2. Contacts we have had with your child (or yourself), such as appointments
  3. Notes and reports on your child’s (or your) health
  4. Details of treatment and care and test results
  5. Information on medicines, side effects and allergies
  6. Relevant information from people who provide care for your child (or yourself) and know you well, such as other health professionals and relatives.
  7. Our clinical staff who provide care may also have notes on their professional opinion.

If you wish us to, and it is practical, we will discuss and agree with you what we are going to enter on our record and show you what we have recorded.

We have many patients with similar names so it is vitally important for all patients to be properly identified as individuals. In order to be sure that you have been correctly identified we may ask you for additional pieces of information regarding your child or yourself. Suitable items include:

• Full name
• Date of birth
• Photo ID, such as a Passport or Driving licence
• Permanent (home, not a temporary) address

• Let us know when your child (or yourself) change address, telephone number, email or name
• Tell us if any information in our record is incorrect
• Give your consent so that we can share information with other health professionals to make sure we provide the most effective healthcare.
• Tell us if you change your mind about how we share the information in your child’s (or your) record.

Please contact us at anytime to update (or to remove) any of the telephone numbers, postal address or emails we hold on file for yourself (or your child). We take privacy very seriously so please let us know how you want us to contact you (or your child, depending on their age).

Telephone

• If you provide a mobile phone number for yourself we may ring, leave a voicemail message or text you, so tell us if you do not want us to do so.
• If you provide a mobile phone number for your child/young adult we will only ring (or leave a voicemail or text) if the communication is age appropriate to your young adult child. For example, if your child is 21 years old, and it is appropriate, we may text them directly regarding an appointment reminder.
• If you provide a landline number we may leave a voicemail message, so please tell us if you do not want us to do so.

Email

• If you provide us with your email address we may use it send confidential health information, appointment bookings & reminders, invoices & receipts, unless you have explicitly told us not to do so.
• If you provide us with the email address of your young adult child we may use it send confidential health information, appointment bookings & reminders, invoices and receipts, unless you have explicitly told us not to do so.

Please read the following before providing us with your (or your young adult child’s) email address:

• Emails can be quick and convenient and will allow a record to be kept (unlike a phone call). However, although our own IT systems are secure, it may be possible to intercept your email when it is being sent over the internet.
• Be aware also that if you share your computer others may read your emails.
• You could use email to contact staff in relation to a query or to ask about an appointment.
• Do not give more personal information than we need to process your request.
• Do not ask us to send you medical details via unsecured email that you would not want seen by other people. We use Egress for secure email communication.

Postal Address

• If you provide a postal address we may use it send confidential health information, unless you have told us not to do so.

Please read the following before providing us with you (or your child’s) postal address:

• Be aware that your postal mail may be intercepted and read (whether intentionally or accidentally) by someone other than yourself.
• Do not ask us to send you medical details that you would not want seen by other people

If you have an urgent question or your child (or yourself) feel severely unwell, or are suffering from any medication side effects, please contact an emergency service, your nearest Accident & Emergency (A&E) hospital or local GP.

Call 999 for life threatening conditions, do not email and do not telephone our clinic, as we are unable to provide emergency assistance.

Our guiding principle is that we hold all patient records in the strictest confidence.

We are registered under the Data Protection Act 1998. It abides by the law and observes good practice in maintaining confidentiality and appropriate information security.

We will fulfill its obligations under this Act to the fullest extent, including ensuring that the following eight principles governing the processing of personal data are observed.

1. personal data shall be processed fairly and lawfully;
2. personal data shall be obtained only for specified and lawful purposes, and shall not be processed in any manner incompatible with those purposes;
3. personal data shall be adequate, relevant and not excessive in relation to the purposes for which it is processed;
4. personal data shall be accurate and, where necessary, kept up to date;
5. personal data shall be kept for no longer than is necessary for the purposes for which it is processed;
6. personal data shall be processed in accordance with the rights of data subjects under the Act;
7. personal data shall be subject to appropriate technical and organisational measures to protect against unauthorised or unlawful processing and accidental loss, destruction or damage;
8. personal data shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of data protection

We are also registered with the Care Quality Commission as “Across The Lifespan Ltd.”. This means that we are subject to ongoing inspection and regulation by the CQC. This includes checks by the CQC that we are observing all necessary and statutory guidelines for use of your data in line with Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (Part 3).

Information about your child (or yourself) and the services we provide may be held in a number of formats and will be kept for the specific retention periods outlined by the relevant professional bodies. We use secure electronic systems to store user records, images and details of prescriptions. Patient data held on paper or disk will be processed in accordance with the Data Protection Act and destroyed using secure documented procedures after the time periods set out by the Department of Health.

We use patient records to:

• Ensure that any treatment or advisory services we provide are based on accurate information.
• Send a letter about the care we provide to your child’s (or your) GP or other health professional during treatment, unless you tell us not to do so.
• Work effectively with other services that are also providing treatment or advice.
• Monitor the quality of our care and help us to understand the outcomes of care.
• Investigate any concerns or complaints you or your family have.
• Provide information that is needed for financial transactions in relation to payment for treatment, such as billing. For patients whom hold private medical insurance or are being referred via an embassy, this may include details shared with your insurance company or embassy. If you have any concerns about this, please contact your insurer or embassy.

We may remove your child’s (or your) name and other details that could identify an individual so that we can use the information in our record anonymously to:

• Monitor and improve the quality of care received.
• Protect the health of the general public, for example we may share anonymous and aggregated patient information with organisations such as the National Institute for Clinical Excellence.
• Train and educate our staff
• Wherever possible, we anonymise all patient data or use a quasi-identifier such as a patient number, a patient pseudonym or patient initials.

We have a designated Data Protection Officer who is responsible for protecting the confidentiality of patient information and making sure that information is shared where this is appropriate.

To make sure we provide the best care and treatment, we may need to share the information in your child’s (or your) health record with other staff and organisations. This could include:

• Other healthcare professionals, such as doctors, psychologists, psychiatrists, pharmacists, and pathology staff involved in the analysis and reporting of any pharmacogenomic tests
• Any hospitals, inpatient units or private sector organisations involved in your care
• Local authority departments
• Voluntary organisations providing on-going support
• Administrative support staff

Note that anyone who receives information from us also has a legal duty to keep it confidential.

We may also share information that identifies your child (or yourself) where:

• You ask us to do so, note we ask for specific permission and you agree to this
• We are required to do so by law
• We have special permission because we believe that the reasons for sharing are so important that they override our obligation of confidentiality (e.g. to prevent someone from being seriously harmed or if it is deemed by our clinicians to be in the patient’s best medical interests according to General Medical Council guidelines).
• We do not give the names and addresses of patients to any other organisations except under the circumstances described in this Privacy Notice.
• Unless you have signed an additional consent, we will not contact you after your visit for purposes other than:
  • Follow up of care
  • Collecting your views about your treatment
  • Settlement of any account that may be due
  • Complaints and concerns handling.

• We may be required to share information about the progress of your child’s (or your) treatment with the person you name as an Emergency Contact, unless you have told us in writing not to do so. The emergency contact should be someone that you trust and feel close to. It does not have to be a blood relative; it can be a good friend. We ask patients to name their emergency contact so that we know who you would like us to keep informed about the care we provide or the decisions we need to make.
• In identifying an emergency contact, you are giving us permission to keep them informed. However, note that since our Company provides principally psychiatric services only, it will not generally be appropriate for us to give general information about a patient’s health and such requests therefore should normally be directed to the patient’s own General Practitioner or other health professional responsible for the patient’s care.
• You can also name other people, with whom you would like us to share information about you. We make best efforts to ensure that information provided over the telephone is restricted to those you have named and that we share only on a need-to-know basis. Sometimes this means refusing to disclose information about your child (or yourself) to someone who feels they should know about the treatment and progress. If this is relevant or appropriate in your circumstances, please make your family and friends aware of this if appropriate.

• Please be aware that we owe a duty of care at all times to act solely in the child’s best medical interests. Therefore, please be aware, that under General Medical Council guidelines, this may include consulting with any and all adults of a child patient, whom hold some parental or guardianship responsibility. If you are separated or divorced from your child’s other parent/guardian, then please keep in mind that the other parent/guardian is entitled under General Medical Council guidelines to provide us relevant information on the child’s welfare, and we are legally obliged to ensure that any such information that may be provided is incorporated into our clinician’s decision making process regarding the medical treatment of your child. If requested, we must also share medical-related information on the child and their progress, treatment and any medication information with the other parent.
• You are responsible for informing any other adult whom also has parental or guardianship responsibility for your child, of the fact that your child is undergoing treatment at our clinic, this includes you notifying them of any medication your child may be being prescribed by our clinic.
• No other non-medical information (e.g. your postal address, email, phone number) will be shared with or divulged to the other parent/guardian if you do not wish us to.

Sometimes we have a legal duty to provide information about people; examples are reporting when a court order instructs us to do so. Records may also be shared without the patient’s consent in exceptional situations, such as to safeguard adults or children.

The Care Quality Commission is the independent regulator of health care and they also protect the interests of people whose rights are restricted under the Mental Health Act. They routinely inspect our premises to quality check information we hold and the services we provide in line with the Health & Social Care Acts. This is designed to ensure that patients using services are protected and receive the care, treatment and support they need. These inspectors have the authority to access personal information without the permission of patients.

If your child’s (or your) permanent address is outside the EU, or the treatment is continuing outside the EU, we may send details of the treatment to individuals based outside the EU specifically to promote ongoing care. This would normally be to any doctor whom may have provided your referral. If you wish, we can give you electronic copies of any such documents so that you have physical control over this information.

In the usual course of our business, we may use third parties to process and store data on our behalf. We normally store your data on secure servers in the European Economic Area (EEA). Such processing is subject to contractual restrictions with regard to confidentiality and security in addition to the obligations imposed by the Data Protection Act 1998.

Exceptionally we may make use our suppliers are based outside the EEA for processing and storing data. We have strict controls over how and why such data can be accessed.  By submitting any of your child’s (or your) personal data, you hereby agree to this.

Where necessary we may transfer personal information outside of the EEA for processing to support the long- term effectiveness of treatment and monitor patient outcomes. Personal information will be processed in this way where it is not possible to achieve this purpose with the use of anonymised or pseudonymised information only.

If you do not want us to share information with your child’s (or your) GP, other healthcare providers or carers, please tell us in writing. But please note that not sharing information may affect the care that we can provide.

You have the right to request that any confidential information is not used beyond your child’s (or your) own care and treatment and to have your objections considered. Where your wishes cannot be followed you will be told the reasons including the legal basis. You may at any time withdraw any consent you have previously given to us to process information.

If you wish to exercise your right to opt-out, withdraw consent to use your information, or to speak to somebody to understand what impact this may have, please discuss your concerns with us, or email with a subject line of “Opt Out Request” in the subject line.

Across The Lifespan Ltd is the Data Controller of the data it holds about its patients and staff.

You also have the right to confidentiality under the EU General Data Protection Regulation (GDPR) 2016/679. Under Article 6 of the EU General Data Protection Regulation (GDPR) the lawful basis category upon which your data is being processed is ‘Legal Obligation’.

You also have the right to confidentiality under the Data Protection Act 1998 (DPA), the Human Rights Act 1998 and the Common Law Duty of Confidentiality. The Equality Act 2010 may also apply.

You have the right to know what information we hold about your child (or yourself), what we use it for and if the information is to be shared, who it will be shared with.

You have the right to apply for access to the information we hold. Other people can also apply to access these health records on your behalf. This can include anyone authorised by you in writing (such as a solicitor), or any person appointed by a court to manage your child’s (or your) affairs. Access covers:

• The right to obtain a copy of the record in a permanent form;
• The right to have the information provided to in a way that it can be understood, and explained where necessary, for example where abbreviations have been used. You would not be entitled to see information that:
  • Has been provided by someone else if they haven’t given permission for you to see it.
  • Identifies another person who has not given permission for you to see the information about them.
  • Relates to criminal offences
  • Is being used to detect or prevent crime
  • Could cause physical or mental harm to your child, yourself or someone else. If you wish to view the record without obtaining a permanent copy, discuss your request with the relevant clinician at our clinic.

If you wish to apply for access to the information we hold:

• You should send your request in writing to us or via email.
• You should provide enough information to enable us to correctly identify the record, for example include your child’s (or your): full name, address, date of birth and any unique identifier number (if known).
• We will take every reasonable step respond to you within 40 days of receiving your request.
• You may be required to provide a form of ID before any information is released to you. Once you receive the record, if you believe any information is inaccurate or incorrect, please inform us.

This Privacy Policy is effective immediately and will remain in effect until further notice.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of our services after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy

If you have any further questions about this Privacy Policy, or if anything is not clear, please let us know.  Further information about data protection issues is at:

The Information Commissioner’s Office (ICO)
Wycliffe House
Cheshire
SK9 5AF
Helpline: 0303 123 1113
Website: www.ico.gov.uk