The General Data Protection Regulation (GDPR) acts as the UK Data Protection Act, 2018. 

About me

I am a certified Play Therapist holding a MSc in Play Therapy accredited by British Association of Play Therapists (BAPT). I am a member of British Association of Play Therapists (BAPT).   I am a qualified Drawing and Talking Practitioner accredited by Drawing and Talking.

Click here to see our Privacy Statement for Parents (PDF)

Collection of Personal Information

1. Information about the client will be collected via spoken or written media from parents, carers or other relevant professional.
2. With parental consent, information may also be collected from other professionals working with the child e.g. school/nursery/children’s centre/Social Care.
3. Information may also be taken about family members where this relates to the child – e.g. contact details for parents and any relevant medical / developmental history.
4. Monitoring data to assess impact will be collected through the completion of a Goodman’s Strength and Difficulties Questionnaire (SDQ). This will be completed at the beginning of Therapy, during the mid-way review and again, at the end
5. Confidential work product of the client that is produced within a Play Therapy setting (e.g. artwork, drawings, clay models, etc) will be collected and stored securely by the Play Therapist

Use of Personal Information

1. Personal information collected via email, telephone contact, online mediums or face to face is stored and used for the purpose of delivering Play Therapy/Drawing and Talking and training/consultancy.  
2. Any sensitive personal details are stored in a secure and confidential system. All computers used are password protected using a complex password combination of numbers, upper- and lower-case letters and punctuation
3. Personal details shall be used for the purpose of delivering appropriate therapy service to the client, corresponding with the client or delivering goods/services to the client/customer.
4. With consent, information about the child’s needs (who is accessing Play Therapy/Drawing and Talking) will be shared with other professionals involved in the child’s care when it is in the child’s best interests.
5. A record of the client’s consent to Play Therapy/Drawing and Talking is kept within the child’s case notes
6. Unless we are required to do so by law, we will not disclose any personal information collected to any person other than as set out above e.g. we will not share information with Teaching Staff at the child’s school who are not involved with the child’s care.
7. We do not employ agents to process personal data – for example, specialist mailing companies to send out communications.
8. We do not give or sell client details to any third parties.

How we use Personal Information

We use personal information collected to:

1. To prepare, plan, and provide therapy services, training workshops and behaviour consultancy, appropriate to the client, adult or professional’s need.
2. To communicate with the child’s parents/guardians and/or therapeutic referrer by post, email, telephone or text message in relation to:

   • Confirming and preparing for appointments

   • General communication in-between appointments

   • Sending reports and programmes for the child, which are password-protected

   • Copying the child’s parents/guardians and/or therapeutic referrer into communications with other professionals about the child

   • Sending resources

   • Sending invoices

3. For management and administration – All information collected and used will be anonymised, client codes will be used, and no personal identifiers will be included.
4. For the personal development of Therapeutic Practitioners – for example, certain client cases may be discussed with a clinical supervisor, but these discussions will be confidential and personal identifiers will not be used.
5. Whenever personal identifiers are not needed for these tasks, we will remove them from the information, if possible.

How We Store Personal Information

1. All information about the child and their therapy is stored securely in a password protected, encrypted folder on Turning Point Child Therapy computer/s. All computers used are password protected using a complex password combination of numbers, upper- and lower-case letters and punctuation. Passwords should be changed every three months
2. We use a comprehensive record-keeping system to ensure there is a clear audit trail.
3. Any paper-based, confidential information (such as assessments and case notes) are stored securely in accordance with data protection regulations. All paper-based records are kept in locked cabinets, carried securely and not left in public areas
4. Any confidential work product of the client that is produced within a Play Therapy setting (eg artwork, drawings, clay models, etc) will be stored in a folder/bag/box. Each client will be allocated their own storage folder/bag/box and these storage cases will either be kept in a lockable storage facility on site of the clients setting or will be stored centrally by the Play Therapist in a lockable storage facility in another convenient and confidential location.
5. External storage devices, including USB sticks and external hard drives that are used for confidential data must be encrypted and not left unattended. Any lost storage devices containing confidential data must be reported and appropriate action taken
6. In accordance with law, all records will be kept securely until the child is 21 years old. After this time, all records relating to the child will be securely destroyed.
   • 6.1 All hard/paper copy records of client files will be kept in a secure locked filing cabinet for 1 year after the client is discharged from Therapy.
   • 6.2 All electronic files will be deleted 3 years after the child’s 18th birthday, when the child turns 21 years old
7. All customer records, including personal information, purchases, invoices and attendance at workshops will be kept for 10 years in case of HMRC financial audit

Breach Procedure

 If any confidential data is lost, damaged or inappropriately accessed, we will:

1. Seek advice from the ICO about how to act.
2. Contact the client if advised to do so.
3. Contact any other relevant agency/organisation if advised to do so

Meeting Professional Obligations

All Play Therapists and Associate Play Therapists at Turning Point Child Therapy are required to be members of a UK based Play Therapy regulatory body (PTUK or BAPT). BAPT has clear standards of conduct, performance and ethics to which all registrants must adhere. These standards affect the way in which we process and share information, specifically the ethical principles of:

Principle A – Responsibility: These Principles are aspirational in nature but are considered good ethical practice for a Play Therapist. Play Therapists need to be motivated, concerned and directed towards good ethical practice. They are required to take responsibility to maintain these standards and Play Therapists should always accept responsibility for their professional behaviour and actions. Play Therapists are concerned about the ethical compliance of their own practice and their colleagues’ professional conduct. When ethical conflicts occur, Play Therapists attempt to resolve these conflicts in a responsible manner. Play Therapists are also aware of their professional responsibilities towards their clients, society and to the communities in which they work.

Principle B – Beneficence: Play Therapists strive to benefit those with whom they work, acting in their best interests and always working within their limits of competence, training, experience and supervision. This principle involves an obligation to use regular and on-going supervision to enhance the quality-of-service provision and to commit to enhancing practice by continuing professional development. An obligation of the Play Therapist is to act in the best interests of clients, and this is the paramount consideration for Play Therapists since clients are generally non-autonomous and dependent on significant others. Ensuring that the client’s best interests are met requires monitoring of practice and outcomes and accordingly BAPT has set down standards for supervision which all members of BAPT should follow.

Principle C – Non-Maleficence: Play Therapists are committed to not harming those with whom they work. Because Play Therapists’ professional judgements and actions may affect the lives of others, they are aware, concerned and committed to guard against personal, financial, social, organisational, emotional, sexual or political factors that may lead to a misuse of their influence or exploitation of those with whom they work. This may involve not providing services when unfit to do so due to personal impairment, including illness, personal circumstances or intoxication. Play Therapists have a responsibility to challenge the incompetence or malpractice of others and to contribute to investigations or adjudications concerning the professional practice and/or actions of others.

Principle D – Fidelity: Play Therapists establish relationships of trust with those with whom they work. Play Therapists honour and act in accordance with the trust placed in them. This principle obliges Play Therapists to maintain confidentiality and restrict disclosures of confidential information to a standard appropriate to their workplace and legal requirements.

Principle E – Justice: Play Therapists recognise that fairness and justice is an entitlement for all persons. This obliges Play Therapists to ensure that all persons have fair and equal access to and benefit from the contributions of Play Therapy and to equal quality in the services being conducted and offered by Play Therapists. Play Therapists exercise judgement and care to ensure that their potential biases, levels of competence and limitations of their training and experience do not directly or indirectly lead to unjust practices. Supervision and CPD There is an obligation to use regular and on-going supervision to enhance the quality of the services provided and to commit to updating practice by continuing professional development.

Principle F – Respect for people’s rights and dignity: Play Therapists respect the dignity and worth of all people and the rights to privacy, confidentiality and autonomy. Play Therapists who respect the autonomy of those with whom they work ensure accuracy of advertising and delineation of service information. Play Therapists seek freely the informed consent of those legally responsible for clients and, where possible, assent from clients, engage in clear and explicit contracts, including confidentiality requirements and inform those involved of any foreseeable conflicts of interest. Play Therapists are aware that special safeguards may be necessary to protect the rights and welfare of clients who are non-autonomous and dependent on significant others.

Principle G – Respect for people’s needs and relationships: Play Therapists respect the needs of individuals, including emotional, psychological, social, financial, educational, health and familial needs. Play Therapists who respect people’s needs and relationships are aware that clients may be dependent upon significant others and that autonomous decision making may not be possible. Play Therapists respect the client’s relationships and ensure that, where possible, those in significant relationships to the client are included in the decision-making processes.

Principle H – Self Respect: Play Therapists apply all of these principles to themselves. This involves a respect for the Play Therapist’s own knowledge, needs and development. This includes accessing opportunities for personal and professional development. There is a responsibility to use supervision for development and to seek training for continuing professional development. Ensuring Play Therapists are appropriately safeguarded by insurance is also a requirement for this principle.

UK Data Protection Law and EU General Data Protection Regulations

Data Protection Law lays down wide-ranging rules backed up by criminal sanctions for the processing of information about identifiable, living individuals. It also gives individuals certain rights in relation to personal data held about them by others.

Turning Point Child Therapy is registered with the Information Commissioner’s Office (ICO) as a data controller. Registration Number:  ZB689088

Our Lawful Basis for Processing Personal Information

Our lawful basis for processing and storing personal information is one of “legitimate interest” (under article 6 of GDPR). We cannot adequately deliver a high-quality therapeutic service without processing the child’s personal information. As it is both a necessity for service delivery and of benefit to the child, we have a legitimate interest to process and store their data.

Data relating to an individual’s health is classified as “special category data” under section 9 of GDPR. The regulations specify that health professionals that are “legally bound to professional secrecy” may have a lawful basis for processing this data. Play Therapists are legally bound to keep client information confidential, and it is under this condition that we process and store personal information.

Our Responsibilities

We are committed to maintaining the security and confidentiality of the client’s record. We actively implement security measures to ensure that their information is safe

We will not release personal details to any third party without first seeking consent unless this is allowed for, or required, by law. Any court requests for a client’s personal data, record of sessions or other information relating to their treatment will be discussed, if possible, with the family and/or child (depending on the age and mental capabilities of the child).

Any reports produced will be respectful towards the sensitive nature of the data, will be compliant towards the justice system and will be based on facts rather than opinions and theoretical hypothesis of the therapist. All data that is legally subpoenaed will be handed over to the court within the appropriate timeframes. In the event that the client has exceeded their 21st birthday and all data has been destroyed, the court will be issued with a copy of this policy.

Your Rights

 Data protection legislation gives the client various rights, the most of important of which are as follows:

• You have the right to a copy of the information that I hold about the child. If the child is 16 years or older, his/her consent is required unless the client has power of attorney.
• You have the right to ask for your record to be amended if you believe that it is wrong.
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How to Access Your Child’s Records

Please contact us in writing if you would like to access your child or young person’s notes (a request cannot be made via email as written signature is required).

Requests should be sent to: Turning Point Child Therapy, The Meadows, Pen y Cwm, Haverfordwest. SA62 6NH

A copy of the child’s records is provided free of charge. Postage costs, however, will be incurred if the records need to be, or are asked to be, sent by post.

We will aim to provide access to the child’s records within 30 days of receipt of all necessary information, providing it is reasonable to do so

Questions

If you have any questions about how we use a child’s personal information, please contact us via email: info@turningpoint.wales  

Further information about data protection and your rights is available from the Information Commissioner’s Office on 0303 123 1113.

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