Privacy Notices - Hearing support team Privacy Notice

You need to be aware of this privacy notice if your child, young person (CYP) has been diagnosed with a hearing loss and a referral has been made to the Hearing Support Team (HST).

A Privacy Notice is a statement issued by an organisation which explains how personal and confidential data about individuals is collected, used and shared.

Your data will be collected by the Hearing Support Team on behalf of Swindon Borough Council.
Swindon Borough Council will act as the “Data Controller” for any personal data that you provide to us. 
We will ensure that the data given to us is processed in line with our Data Protection Act 2018 (DPA 18) and the EU General Data Protection Regulations. (GDPR)

To find out more about Swindon Borough Council’s data protection policies please contact our Data Protection Officer. dataprotection@swindon.gov.uk or in writing to:

Data Protection Officer
Civic Offices
Euclid Street
Swindon
Wiltshire.
SN1 2JH.

Please note that not providing your personal data may lead to you being unable to utilise services provided by the Hearing Support Team.
 

‘Personal data’ means any information relating to an identified or identifiable natural person (the ‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

The Hearing Support Team hold individual paper files and entries in an electronic database of all Children and Young People (CYP) referred to our service. This includes those CYP who are no longer on active caseload because they have been placed on our ‘on request’ caseload.

For CYP who have been discharged from our service caseload, paper files and/or electronic files are also held in accordance with the relevant retention schedule (see below).

For each CYP on the HST electronic database, we hold the following information:

• Name
• Date of birth
• Ethnicity
• Gender
• Parents/guardians names
• Signatures
• Address and contact details, including telephone numbers and email addresses
• Type/degree of hearing loss and type of hearing technology worn
• School placement and year group
• Radio aid technology used and serial numbers/transmitting channels of any equipment issued by HST to a child
• Primary and secondary SEND category (in accordance with our SEND categories)
• Dates of last annual review meetings
• Hospital audiology team details
• Hospital number
• Details of initial referral, contact dates
• Details of when a child was moved to the ‘On Request’ caseload
• Details of visit allocations/frequency of visits to CYP from HST staff
• Medical information

In addition to the above, paper files on CYP may also contain:

• original initial referral form with information as above
• audiograms and information from audiology/auditory implant teams
• first fit of hearing aid letter
• NATSIP support allocation summary
• a copy of the most recent ECHP/statement if applicable
• medical information relevant to our involvement with the CYP, for example, paediatrician/ENT/OT/Physio/SLT reports)
• radio aid fitting details and loan letter agreement
• school progress information
• HST specific assessment results and forms
• where there are Child Protection (CP) issues around a CYP there may also be a sealed envelope in the file marked ‘Confidential – CP’ containing CP related information

We also hold additional electronic files on CYP, normally containing information such as:

• copies of the referral which are scanned on initial receipt
• the HST assessment report which includes audiogram information
• the HST records of visits
• the HST reports for annual reviews/EHR meetings
• a journal for recording other contact with CYP/families/schools, for example, telephone conversations, visits to make earmould impressions
• electronic or scanned reports from other professionals. Any paper copies are scanned and shredded to keep paper files to a minimum.
• scanned audiograms over time
• data trackers
• progress information from schools if sent electronically

We comply with our obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
 

Data we hold is used by HST staff in the following ways:

• To support CYP on our caseload
• To track progress of CYP on our caseload
• To provide references for CYP
• For Safeguarding related purposes
• For allocating caseloads to staff equitably
• For collating information about our caseload population required by the Local Authority. When we are asked to report information of this nature it is always pseudonymised and no single CYP are identified within the report.
• For collating information for the HST Service reviews. When we are asked to report information of this nature it is  always anonymised and no single CYP are identified within the report.
• For replying to Freedom of Information (FOI) requests. For example the NDCS always send us an annual information request about caseloads, Teacher of the Deaf numbers, finances and support levels. When we are asked to report information of this nature it is always anonymised and no single CYP are identified within the report.

In addition, we require consent from parents and CYP to use their data for:

• sending out information via email about additional services (such as the Children’s Hearing Services Working Group - CHSWG)
• advising CYP and parents via email about social opportunities for Deaf CYP in the area
• advising parents via email about any events being run by the Hearing Support Team
• distributing our team Newsletter or similar communications via e-mail which may be of interest to families of deaf CYP
• seeking feedback and comments from parents via e-mail about our service and how we can improve it

In accordance with Article 6 of the GDPR, we collect and use data based on 4 of the permissible lawful basis:

• ‘Public task’ (data is necessary to allow us to function, eg contact details so that we can send out reports; nature and type of hearing loss so that we can advise accordingly)
• ‘Legitimate Interest’ (data is necessary for our legitimate interests eg progress data from schools so that we can support and monitor academic progress of our CYP)
• ‘Legal Obligation’ (data is necessary to comply with the law 2014 Children and Families Act)
• ‘Consent’ has been explicitly given (eg. email contact details used to distribute the HST newsletter)

We share our Advisory Teacher of the Deaf reports, data and information with the CYP’s school, nursery or educational setting in order to support their needs.

We may share reports, data and information with other professionals who are directly involved in supporting your child’s needs within an education, health or social care setting or if required to do so by law.

We are also obliged to share CYP’s data with the Department for Education (DfE) on a statutory basis. This data sharing underpins school funding and educational attainment policy and monitoring.

In accordance with the Information & Records Management Society, Retention Guidelines for Schools, we keep data, both on paper and/or electronically on CYP until they are at least 25 years old.

Records for CYP who are discharged from our service before the end of their time in formal education are kept as a minimum until the child is age 25 or for 12y following discharge (whichever is the later date) and then deleted/destroyed.

Once the relevant time period has elapsed, any paper copies of data and records for CYP will be destroyed via a secure disposal system and electronic data will be erased from our computer systems.

In accordance with the Information & Records Management Society, Retention Guidelines for Schools, we keep data, both on paper and/or electronically on CYP until they are at least 25 years old.

Records for CYP who are discharged from our service before the end of their time in formal education are kept as a minimum until the child is age 25 or for 12 years following discharge (whichever is the later date) and then deleted/destroyed.

Once the relevant time period has elapsed, any paper copies of data and records for CYP will be destroyed via a secure disposal system and electronic data will be erased from our computer systems.
 

Unless subject to an exemption under GDPR you have the following rights with respect to your personal data:

• The right to request a copy of your personal data which we hold about you
• The right to request that we correct any personal data if it is found to be inaccurate or out of date
• The right to request your personal data is erased where it is no longer necessary for us to retain such data
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing
• The right to object to the processing of personal data
• The right to restrict what we use your data for
• The right to object to decisions based on your data being made by automated means (such as by a computer)
• The right to ask for your information to be moved to another provider
• The right to lodge a complaint with the Information Commissioners Office

For further details on how your information is used, how we maintain the security of your information, and your rights to access information we hold on you please contact the Senior Advisory Teacher of the Deaf on 01793 544021 or via HSTAdmin@swindon.gov.uk or contact the Data Protection Officer at:

Swindon Borough Council
Civic Offices
Euclid Street
Swindon
SN1 2JH
 

In the event that you wish to complain about the way that your personal data has been handled by the Hearing Support Team or by Swindon Borough Council, you should write to the Hearing Support Team and/or the Data Protection Officer and clearly outline your case.

Your complaint will then be investigated in accordance with the SBC customer complaint procedure.
If you remain dissatisfied with the way your personal data has been handled, you have the right to complain to the Information Commissioner’s Office at www.ICO.org.uk.

The ICO website also contains information on data protection and your rights and remedies.

If you do not provide data to the Hearing Support Team:

• we will not be able to support your child to the best of our ability, or at all
• we will not be able to share useful and important information with other professionals to help them to support your child

As well as adhering to this privacy notice the HST have a data protection and data handling policy which ensure that all staff within the HST follow current Data Protection regulations.

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