PRIVACY NOTICE – PERSONAL INFORMATION ABOUT OUR CLIENTS, *SECOND AND *THIRD PARTIES

*Second and third parties consist of a learner’s carer(s), parent (s), therapists, school staff and any other person’s with whom I am authorized to discuss the learner with prior consent.

Personal information is a combination of information that would enable someone to identify a person.

1. Personal information I use

I hold or will collect your personal information from you directly, or as part of the service provided to my clients (also called learners in this document). The information will be given to me by the learner’s immediate carer(s) or parent(s).

1.1. What information I may collect from you/about you?

(a) Personal details (for example, your name and details about the learner such as where they live and where they attend school).

(b) Your contact details (for example your address if you are the immediate carer, addresses of settings where the learner is supported when they’re not at home, phone number and e-mail).

(c) Details about other people working with the learner who would be receiving training and advice from me.

(d) I will also ask about the learner’s routine, their daily life and questions originated from the behavioural analytical assessments I work with which have been described to you during the initial assessment process.

(e) Data required as part of the learner’s ABA programme targets and individual protocols.

1.2. What information I collect from other sources (such as therapists and school)?

(a) Personal details (for example, name and role in the learner’s ABA Programme or in a setting different to the home. Examples of roles can be ‘ABA therapist’ or ‘teacher’).

(b) Contact details (for example the address of people supporting the learner in settings other than their home, phone number and e-mail address).

(c) I will also ask about the learner’s routine, their daily life and questions originated from the behavioural analytical assessments I work with which have been described to you during the initial assessment process.

(d) Data required as part of the learner’s ABA programme targets and individual protocols.

1.3. How will I use your personal information and why?

(a) Communicating with you.

(b) Providing notes, protocols, data analyses and reports about the learner.

(c) Providing consultations in person at your home or setting other than home, providing video or phone consultations.

2. INFORMATION SHARING

2.1. I may need to share personal information when:

(a) I am communicating with my own field practice supervisor (details can be given at request).

(b) Referring enquiries to another Keys For Learning supervisor in your area.

(c) To refer you to another practitioner listed with Keys for Learning who may provide you with services in your area.

(d) When I am providing updates about the learner with authorized persons.

3. SECURITY AND STORAGE

I have in place measures to ensure the learner’s data and personal information about the learner and people working with the learner is kept confidential.

I review these measures regularly to make sure they remain appropriate, and in line with the Professional and Ethical Compliance Code for Behaviour Analysts (established by the Behaviour Analysis Certification Board- BACB), which I abide by in my role as an Applied Behaviour Analysis Consultant (Section 2.6- Maintaining Confidentiality, 2.7- Maintaining records, 8.04- Media presentation and Media Based services, 9.04- Using confidential information for Didactic or Instructive purposes, 9.09- Accuracy and use of data). I also maintain data confidentiality guidelines in place by adhering to existing data protection laws in place which now include the GDPR.

When sharing your personal information with any third party, I will always ensure I will ask for your permission, if not previously obtained, and that I will have measures in place to protect it and keep it confidential. Information will only be shared for the purposes we set out together.

I will keep your personal information for as long as we have a relationship and for a minimum or 7 years, after our relationship ends or more as otherwise required by law.

When deciding how long to keep your personal information after our relationship has ended, I am taking into account my obligations as per the ethical compliance code for behaviour analysts the existing law. I may also retain records to investigate or defend potential legal claims.