Privacy Policy for Orange Psychology Ltd

 

Data Protection; Parents, Carers, Schools, Children & Young People

Orange Psychology Limited will manage personal and professional data with upmost concern for privacy and confidentiality and in accordance with current professional and legal standards, including the provisions of the General Data Protection Regulation (GDPR) requirements. The GDPR requires us to identify the legal basis upon which we process personal data. We will proceed with an assessment and all associated activity on the basis of our contract with schools/other settings and our legitimate interest to hold and process personal data. The following information stipulates how Information is used by a Psychologist at Orange Psychology;

 

Types of Information Processed

When consent has been given for Psychology involvement with a child, family or young person, information in relation to the person will be collected, held and used by the Psychologist (see form below). Depending upon the nature of our contract with the client, we have a legitimate interest to collect data for the purpose of forming a professional opinion.  In doing so, we will only collect information that is relevant to the purpose of undertaking that assessment and the associated feedback and reporting.

Orange Psychology Consent Form; OP Consent Form Sept 2018

Information in relation to the person might include their name, address, date of birth, assessment findings, health, medical and care details, personal views and family background. Some of the information gathered may be sensitive information e.g. safeguarding information, or ‘personal data’ i.e. data relating to a person that can be used to identify a person. As well as collecting information about the person for whom consent has been received, personal information about other people may also be gathered, for example their family members. This information will only be gathered and used where the Educational Psychologist deems it relevant to the persons circumstances, the circumstances for which Educational Psychology involvement has been requested. Information in relation to the person will be collected by the Educational Psychologist directly from the person or indirectly from other sources, such as parent/carer or other professionals involved with the person.

Parents and schools will only be asked for information that is relevant for the work being undertaken. The information that will be requested and held will enable the professional working with a parent or child/young person to decide:

  • -What kind of involvement is appropriate
  • -What tests and assessments should be used; and
  • -Whether liaison with other professionals is needed

 

Why the Information is Collected and Used

The intended purpose for processing personal data is to conduct a psychological assessment/consultation. We need to process personal data in order to fulfil our contractual obligations to undertake this. The Psychologist will not use the data for any other purpose. The Psychologist will only become involved with a child when signed consent for their involvement is received from the child’s parent or other adult with parental responsibility. We will process all personal data that is shared with us for the purpose of the assessment and will do so lawfully, fairly and in a transparent manner. Therefore, processing of personal data is necessary if we are to fulfil our contract with schools, Local Authorities and other settings.

The specific work carried out will vary according to the individual’s needs and the concerns being investigated. The list below shows the range of supportive activities that might be carried out:

  • Classroom observation
  • Observation in other settings in school, for example in a small group teaching session or nurture group;
  • Discussion with the Special Educational Needs Coordinator (SENCo), or head of learning/student support if the setting is FE or HE college;
  • Discussion with class teacher/form tutor and any other school/college staff (for example, Teaching Assistant, Mentor, School Counsellor, head of year);
  • Work alongside the child or young person in class (for example, in Foundation Stage it is often more helpful to assess a young child through the usual play activities that are offered);
  • Individual assessment work. This might involve using tests, questionnaires or interview techniques for eliciting views;
  • Discussion with other external professionals who are working with a parent or child/young person (for example, speech therapist, learning support teacher);
  • Scrutiny of reports or other written information completed by other external professionals working with you or your child/young person;
  • Scrutiny of school/college information, including SEN records;
  • Therapeutic work or Group work.

 

Who the Information is Shared With

The Psychologist will share some or all of the processed information with the person for whom consent for Educational Psychology involvement was received (depending on age and ability), and the organisation/person that requested Psychology involvement. The Psychologist will not share the data with other parties without the consent of the parent/carers, apart from within exceptional circumstances where the law allows the Psychologist to do so. We would have to disregard any promises of confidentiality if we thought a child, young person or adult was in any kind of danger and would be harmed, or cause harm, if we did not disclose some information about them or intervene in some way. Under these circumstances the need to keep someone safe from harm over-rides the duty to keep information about them confidential.

Exceptional circumstances in which data may be shared with other agencies without consent from the parent/carer include circumstances might be where there is immediate risk of substantial harm to self or others; or under a legal requirement, e.g. terrorism, drug money laundering; or via court order for disclosure.

 

Why we Share Pupil Information

We share information so that a child’s needs can be understood and addressed. The school or college will also send parents/carers a copy of any written report or summary that is completed. The report or summary may also be shared with other external professionals who are currently working with the child/young person.

The law allows us to share personal information in some circumstances, provided it has been anonymised. For example, we might discuss the work we have done with a child with other professionals in order to gain advice and to check that we are drawing reasonable conclusions and making good decisions. This is called supervision and it is common for professionals in health, care and education roles to ask for advice from their colleagues in this way. If we do discuss the work we have done in supervision, we will not pass on personal information that would allow another professional to identify a child. We might also show any written report or summary to other psychologists in a face to face supervision meeting, in order to obtain feedback about the quality of the report. These psychologists are also bound by confidentiality and data protection rules, so they would not keep a copy of any personal information.

 

How Information is Stored

The work carried out with a parent or child/young person will initially generate some paper information. For example, the professional will make some handwritten notes about work undertaken or will complete a paper test record booklet. This paper information will be used to create electronic written reports and/or summaries. In giving consent for Orange Psychology Ltd to work with you (as parents or children) you are giving permission for written report or summaries to be completed and for copies to be sent to the school or college. Paper formatted information will be locked away in a lockable cupboard/filing cabinet. Electronically formatted information will be stored in encrypted cloud storage.

Reports and summaries are stored on secure cloud storage systems and are sent to school as password protected pdf documents. Information in relation to the person will be held, as a minimum, for as long as is reasonably needed for the purposes explained in this notice (above). Information on a secure cloud storage systems will be retained for 10 years, or until the individual reaches the age of 25. The persons data will be destroyed by deleting the electronically stored data and shredding the paper stored data. Handwritten file notes will be retained until the case is closed.

 

Requesting access to personal data

Under data protection legislation, parents and pupils have the right to request access to information about them that is held by the Psychologist. To make a request for your personal information, or be given access to your child’s educational record, contact Dr Joanna Mitchell (mail to: enquiries@orangepsychology.co.uk).

Parents/carers also have the right to:

  • object to processing of personal data that is likely to cause, or is causing, damage or distress
  • prevent processing for the purpose of direct marketing
  • object to decisions being taken by automated means
  • in certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed; and
  • a right to seek redress, either through the ICO (Information Commissioners Office, see https://ico.org.uk/for further information), or through the courts

If you have a concern or complaint about the way your personal data is collected or used you should raise your concern with the Educational Psychologist at Footsteps Psychology in the first instance.

 

Data Protection; Online & Website

 

This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally identifiable information’ (PII) is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.
What personal information do we collect from the people that visit our blog, website or app?
When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, phone number or other details to help you with your experience.
When do we collect information?
We collect information from you when you place an order, fill out a form or enter information on our site.
How do we use your information?
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
      • To personalize user’s experience and to allow us to deliver the type of content and product offerings in which you are most interested.
      • To improve our website in order to better serve you.
      • To allow us to better service you in responding to your customer service requests.
How do we protect visitor information?
We do not use vulnerability scanning and/or scanning to PCI standards
We use regular Malware Scanning.
We do not use an SSL certificate
      • We do not need an SSL because:
Personal information such as contact name, email address, telephone number and postal address are not private. SSL doesn’t really protect information that is already publicly available.
Do we use ‘cookies’?
Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
We use cookies to:
      • Understand and save user’s preferences for future visits.
      • Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.
If you disable cookies off, some features will be disabled It won’t affect the users experience that make your site experience more efficient and some of our services will not function properly.
However, you can still place orders .
Third Party Disclosure
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Google
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We use Google AdSense Advertising on our website.
Google, as a third party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on their visit to our site and other sites on the Internet. Users may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy.
We have implemented the following:
      • Google Display Network Impression Reporting
      • Demographics and Interests Reporting
We along with third-party vendors, such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions, and other ad service functions as they relate to our website.
Opting out:
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.
California Online Privacy Protection Act
CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf
According to CalOPPA we agree to the following:
Users can visit our site anonymously
Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website.
Our Privacy Policy link includes the word ‘Privacy’, and can be easily be found on the page specified above.
Users will be notified of any privacy policy changes:
      • On our Privacy Policy Page
Users are able to change their personal information:
      • By emailing us
How does our site handle do not track signals?
We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third party behavioural tracking?
It’s also important to note that we allow third party behavioural tracking
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under 13.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify the users via email
      • Within 7 business days
We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
      • Send information, respond to inquiries, and/or other requests or questions.
      • Process orders and to send information and updates pertaining to orders
      • We may also send you additional information related to your product and/or service.
      • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred
To be in accordance with CANSPAM we agree to the following:
      • NOT use false, or misleading subjects or email addresses
      • Identify the message as an advertisement in some reasonable way
      • Include the physical address of our business or site headquarters
      • Monitor third party email marketing services for compliance, if one is used.
      • Honor opt-out/unsubscribe requests quickly
      • Allow users to unsubscribe by using the link at the bottom of each email

If at any time you would like to unsubscribe from receiving future emails, you can email us at

enquiries@orangepsychology.co.uk and we will promptly remove you from ALL correspondence.

Contacting Us

If there are any questions regarding this privacy policy you may contact us using the information below or by using the contact box below.

 32 Grains Road
Delph
Greater Manchester
OL3 5DS

United Kingdom

email: enquiries@orangepsychology.co.uk
Last Edited on 4/12/18