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D-Restricted Ltd:®

Privacy & Cookies Notice

 

We at D-Restricted Ltd take your privacy very seriously.  D-Restricted Ltd will only ever use your information for admin purposes for your infant’s medical records, and continuity of care.  This is in order to provide accurate treatment and care to the parent-baby dyad; that you have sought from D-Restricted Ltd.

Your information is NOT passed on to third parties, and D-Restricted Ltd do NOT subscribe you to mailing lists.

D-Restricted Ltd may contact you (usually via secure Email) after a consultation for an agreed timeframe with the caregiver(s) as part of the ongoing care/follow-up service.

As part of medical record keeping; a secure HIPPA and GDPR UK compliant software has been installed to further protect you and your ‘Patient Identifiable Data’ (PID). This is instantly in place at point of the caregiver booking their consultation and commences formulating medical documentation.  The software provides a portal for you to manage your booking, and securely allows you to view and access any information D-Restricted Ltd holds which has been provided by you.  The assessment, and any treatment, or suggestions are also recorded and securely accessible by the caregiver(s) who will have set up a password, and ‘2 factor authentication’ to their profile portal.  The software is provided by jane.app and their ‘Privacy notice’ for further details can be found at: https://jane.app/legal/privacy-notice.

 

 

At your appointment, you will be asked to sign to say that you agree to this 'Privacy Notice' as set out below:

This privacy notice only covers D-Restricted Ltd (www.tongue-tie.info  and its associated domains).  It does not cover any websites that can be linked/accessed to via them.  You should always be aware that when you are moving to another site to read the ‘Privacy Statement’ on that site too.  This includes if D-Restricted Ltd were to recommend a site to read for your information only, which may be sent to you via Email or MMS/SMS text, but also if you choose to 'like' or join any related social media pages, such as the D-Restricted Ltd FaceBook support group https://www.facebook.com/groups/219881955258950/ or Instagram page.

Should you choose to leave written feedback on or through www.tongue-tie.info then your PID details will be anolysed. Should you choose to leave feedback through any externally managed software, (such as google reviews) where D-Restricted Ltd is not the data controller, D-Restricted Ltd can not be held accountable for how your data is managed.

 

 

The Data Protection Act (1998)

The GDPR (General Data Protection Regulations) enhances and replaces the current Data Protection Regulations as of 25/05/2018.  Anyone who holds personal data of any EU citizen through personal identifiable records and mailing lists are obliged to comply.

Under the Data Protection Act (1998) D-Restricted Ltd has a legal duty to protect any information held about you.  D-Restricted Ltd use leading technologies and encryption software to safeguard your personal information and keep strict security standards to prevent any unauthorised access to it.

D-Restricted Ltd DOES NOT pass your details on to any third parties.  There are 2 exceptions to this:

  • Your GP needs to be informed of any treatment/procedure undertaken. Minimal identifiable data is included on this letter and D-Restricted Ltd currently uses Royal Mail post to send this to them. If during your consultation D-Restricted Ltd suspect additional minor health factors these may also be included this on the GP letter too.

  • Should D-Restricted Ltd have concerns relating to the welfare of an infant or adult D-Restricted Ltd believes to be "at risk" to self or others, safeguarding concerns or health complications out of my sphere of practice, D-Restricted Ltd may contact other professionals for additional intervention, thus breaching confidentiality.  This may include the GP, Health Visitor, Social Worker or Police. This is both a legal and moral obligation I have to abide to.

 

How will D-Restricted Ltd use the information held against me?

To provide continuation of care by D-Restricted Ltd only, through assessment, treatment and support, as appropriate throughout your feeding journey for you and your infant.

In order to care for/be accountable to the parent-infant dyad, it is necessary for D-Restricted Ltd to hold your personal information, but it is also a legal requirement to do so as recognised by the NMC (Nursing and Midwifery Council) who stipulate that records are to be kept for 25 years post last contact made.  After the 25 years has passed, the records are securely destroyed (cross-shredded, erased, or burnt etc).​

D-Restricted Ltd may use your infant's information, anonolysed, without notice; for auditing or research purposes.

Online submission of personal information

This website is powered by Wix (www.wix.com). The online submission of your details when booking or contacting me are sent via Wix and jane.app (the Data Processor) to myself (the Data Controller)-for both booking and appointment, or completing feedback.  Please note that Wix.com is certified under the EU-US Privacy Shield Framework and the Swiss-US privacy shield framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union to the United States, and therefore adheres to the Privacy Shield Principles.  Their platform also claims to be compliant to the new GDPR regulations from May 2018.  The jane.app privacy notice I found here and is also compliant to HIPPA and GDPR UK regulations.

https://jane.app/legal/privacy-notice.

 

PCI Compliance

All merchants, regardless of the size of their company who process card payments have to comply with PCI DSS.

Your payments are processed through 'Stripe' (card payment processor) who are compliant in this instance as your card payment details are not visible to D-Restricted Ltd. Further information from them is found here:     https://stripe.com/docs/security   

Should you have concerns re fraud or card data use since using your card details, you are encouraged to contact your card provider immediately. 

Cookies

This site uses cookies; small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping baskets, and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on  www.tongue-tie.info and / or on others. The most effective way to do this is to disable cookies in your browser. D-Restricted Ltd suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.

What information do you hold about me/my child?

The records that have been made at your assessment appointment, treatment/procedural appointment, and any written follow ups/notes made.  These have been made in conjunction with the caregiver(s) and are accessible for you to view in the patient profile portal that you originally created.

There is also a CCTV camera to the front and rear of the property: which captures images of you entering the building and the immediate vicinity. Images are stored for 30 days before deletion. 

 

Photographs

D-Restricted Ltd take 'before' and 'after' photographs as a visual aid for documentation, and is of your infant's mouth area only.  Photographs are taken with your knowledge, and may be utilised for training, online publication (website and facebook group) or related demonstration purposes only and will only be done so with your signed consent/agreement. 

Please note that if you are to send photographs/videos to D-Restricted Ltd’s electronic devices (text, Whatsapp!, messenger, email etc) to observe feeding behaviours during the aftercare period these photos are automatically saved to the device utilised. D-Restricted Ltd are the only authorised access to use these devices and are both fingerprint and password protected should it become mislaid.  These photos are saved to your infant's records & once uploaded they are deleted from the devices history.

Accessing copies

When booking your consultation, you will have made a ‘patient profile portal’.  In this portal you can manage your appointments, and view electronically all of the records I hold against you and your child with instant access.  Should you forget your password to access these please make contact with me and I can reset this for you.

If caregiver(s) would prefer a paper copy of their records they are encouraged to request them from me.  D-Restricted Ltd can print this off for you at your appointment, or we can arrange a time to collect them.  Emailing or posting documentation/records is not a secure way to transfer and protect your personal sensitive information.  

Your records will be available to you, free of charge, within 10 working days of the request being received. Upon receipt of receiving the record D-Restricted Ltd will require identification (child’s red health care book/eRedBook, NHS number, Proof of address, date of birth) and a signature to say you have received it.

If in the event D-Restricted Ltd has ceased trading, measures are in place to allow you to still access your records. You would need to contact the ICO to trace the appointed data controller: stating business name: D-Restricted Ltd and Membership number: ZA100466. That will give you the details of who to contact.

What if D-Restricted Ltd is unable to fulfil the appointment(s)?

In the event that D-Restricted Ltd is unable to commit to your consultation time (i.e through sudden illness or an emergency unplanned event); you will be informed of this as soon as D-Restricted Ltd is able. A full refund will be made so you may be able to arrange another appointment with another practitioner as soon as possible (www.tongue-tie.org.uk/find-a-practitioner).

In the event of sudden serious illness where D-Restricted Ltd would be unable to contact you, or in the event of death, all appointments would be cancelled by a third party (also healthcare professional who is DBS checked) and arrange the refund as able. Of course the nominated person will need to gain access to your name, telephone number and payment details in order to do so and access to this is protected so may take a while for them to access this information legally.   The Association of Tongue-tie Practitioners (ATP) would be made aware to remove D-Restricted Ltd name from their approved listings/directory, and notices would be put on both of the websites and social media pages. Patient records will still be available should you wish to view them for 25 years post division as per legal obligation. If D-Restricted Ltd is deceased, Please contact ICO (details below) for details of the successor who will be able to arrange this for you ensuring you can provide the required formal identification.

Your right to withdraw

Until you have achieved your infant feeding goals, D-Restricted Ltd prefers to contact you periodically to assist/guide/support you on your feeding journey.  This maybe through signposting you to information and alternative websites via text or Email, or for a service review.  Once you are happy and discharged from my care, D-Restricted Ltd is obligated by law to hold your records for a further 25 years. 

You may 'opt-out' of any follow-up texts/support at any point.

Should you wish to withdraw from future correspondence regarding the feeding related care of your child you may do so at any point. Either inform me at your appointment that you wish no further contact, in response to the correspondence D-Restricted Ltd will give to you, or by checking the relevant opt-out box in your patient profile portal.

How are my records stored?

Active records (from point of initial contact up until formal date of agreed discharge) are held using Jane.app software and thumb drive memory storage x2 as a back-up. All devices are password protected with additional fingerprint recognition to access emails, and thumb drive memory sticks have encryption properties.  This is so that there is always a minimum of 2-3 copies in D-Restricted Ltd possession.

Both active and dormant records are held in a locked safe, which is stored in a locked fire proof cabinet, in a locked clinic room.  The clinic room has both a motion sensor burglar alarm and the external building also houses CCTV camera.  D-Restricted Ltd also have business level anti-virus/spyware Protection too.

I wish to make a Data Protection related complaint

The ICO (information Commissioner’s Office) is the regulator of the GDPR (General Data Protection Regulations) and complaints should be forwarded to them if it is related to a breech in data collection or record keeping. D-Restricted Ltd is registered with ICO, Membership number ZA100466.  www.ico.org.uk , telephone: 0303 123 1113.

Head Office,

Information Commissioner’s Office,

Wycliffe House,

Water Lane,

Wilmslow

Cheshire,

SK9 5AF

If you have any questions about these terms and conditions, or the practises of D-Restricted Ltd please contact me in writing at:

 D-Restricted Ltd, 31 Avondale Road, Barlestone, Nuneaton, Warwickshire CV13 0HX,

Email diana@tongue-tie.info

Telephone 07910608179.

© DIANA WARREN IBCLC, RGN

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