Privacy Policy
Summit Psychology Services
This Privacy Policy outlines how Summit Psychology Services (Summit) handles the personal information of our service users. When we refer to “service users,” we mean children, young people, families, clients, and other individuals or organisations who receive our psychological and therapeutic services. Whether working directly with individuals or through organisations (such as schools), Summit is committed to protecting your privacy.
For services through organisations (e.g., schools), the school is the data controller, and Summit is the data processor. When working directly with individuals (children, young people, or families), Summit acts as the data controller. Summit Psychology Services’ data controller is Dr Dawn Bradley, ICO Reference: ZA243400, with a registered address at Summit Psychology Services, 15 High Street, Newcastle-Under-Lyme, Staffordshire, ST5 1RB.
Key Privacy Principles
Summit’s team of practitioners includes psychologists and therapists, all of whom follow the ethical standards and guidelines of the British Psychological Society (BPS) and the Health and Care Professions Council (HCPC). We adhere to the following principles when managing your personal information:
• We keep your information safe and secure.
• We will ask for your consent before sharing your personal information, except in cases where disclosure is legally required (e.g., safeguarding).
• If we need to use your information for reasons unrelated to your care, we will obtain explicit written consent.
• We only share the necessary information and will notify you when we do so, where possible.
• Records of any data disclosures will be maintained.
• We stay updated with legal obligations and best practices in data protection.
• We may consult with professional bodies or seek legal advice when needed before sharing information.
Your Rights and Our Responsibilities
In line with HCPC Standards of Conduct and BPS ethical guidelines, Summit’s psychologists and therapists commit to:
• Promoting and protecting your interests.
• Communicating clearly and effectively.
• Working within our expertise and competencies.
• Respecting confidentiality.
• Taking action on concerns related to safeguarding or safety.
• Keeping accurate records of our work.
All psychologists at Summit are accredited with the British Psychological Society (BPS) and the Health and Care Professions Council (HCPC), and our therapists are accredited with the appropriate regulatory bodies relevant to their professions. These accreditations ensure that our team maintains high standards of professional training, skills, behaviour, and ethics.
Confidentiality
Confidentiality means protecting personal details that are private to you. This may include family background, health information, or other sensitive details.
Summit’s psychologists and therapists collect and use personal data only when relevant to your case. This may include, but is not limited to:
• Family details, lifestyle, and social circumstances
• Educational records, health information, and special needs
• Racial or ethnic background, religious beliefs, or other philosophical views
• Information on criminal convictions (protected similarly to sensitive data)
Why We Process Your Information
We process personal data to provide psychological and therapeutic services, fulfil legal obligations, and maintain records. For processing ordinary personal data, we comply with several legal frameworks, including but not limited to:
• Education Acts 1944 and 1996
• Children Acts 1989 and 2004
• Children and Families Act 2014
• GDPR and Data Protection Act 2018
Consent
We operate on both implied consent and explicit consent, depending on the situation:
• Implied Consent: If you use our services, we assume you consent to us handling your information for your care.
• Explicit Consent: For situations involving sharing your information outside our services, we will ask for explicit written consent.
For consent to be valid, it must be:
1. Voluntary: You make the decision without pressure.
2. Informed: You fully understand what you’re consenting to.
3. Capacity: You can understand the decision you’re making.
For children under 16, we will usually obtain consent from someone with parental responsibility. Some children under 16, if deemed capable of understanding (called “Gillick competence”), can give consent themselves.
Withdrawing Consent
You can withdraw consent at any time. If you do so, we will delete your file (electronic versions) and related documents. However, some records (such as conversations between therapists, psychologists, and other practitioners) may remain on file where legally required.
Sharing Your Information
We only share your personal data when necessary for your care or when legally required. This may include sharing information with:
• Schools, educational bodies, healthcare professionals
• Social and welfare organisations
• Government agencies, courts, or law enforcement (in cases like safeguarding or legal obligations)
Before sharing your data for reasons not directly related to your care, we will always seek your written consent.
Public Interest
In certain situations, Summit Psychology Services may disclose confidential information without consent if it is in the public interest. This may include instances where disclosure is necessary to prevent a serious crime or harm to others.
Who Makes Public Interest Disclosure Decisions?
Decisions regarding public interest disclosures are made by senior practitioners at Summit, including our psychologists, therapists, and the safeguarding lead. The safeguarding lead, Dr Dawn Bradley, plays a critical role in decisions related to the protection of children, young people, or vulnerable adults, especially in cases involving safeguarding concerns.
When a public interest disclosure is considered, we:
1. Assess the situation with the relevant practitioner.
2. Involve the safeguarding lead, particularly in safeguarding cases.
3. Seek legal or professional advice when necessary.
4. Balance the potential risks of disclosure versus non-disclosure.
Where possible, we inform the service user or their legal guardian before disclosing information, unless it is not appropriate in safeguarding cases or preventing a crime.
Data Retention and Storage
Summit stores both paper and electronic files securely. After 36 months, paper files are digitised, and the physical copies are destroyed.
• Retention Periods: We retain records for 7 years for adults and until the child reaches 25 years of age.
• Storage Security: All electronic records are stored on encrypted hard drives, secured in locked locations within a locked office.
• When working within organisations (e.g., schools), their policies govern how long records are kept.
Accessing Your Information
You have the right to see any personal information we hold about you. To request your data, please email us at support@summitpsychologyservices.co.uk
Safeguarding
At Summit Psychology Services, safeguarding is a central aspect of our work with children, young people, vulnerable adults, and adults at risk. We are committed to promoting their welfare and protecting them from abuse. Our actions follow the procedures laid out in our Safeguarding Policy, which aligns with relevant UK legislation.
Key Responsibilities:
• Dr Dawn Bradley, the Director of Summit Psychology Services, holds overall responsibility for safeguarding.
• Day-to-day safeguarding responsibilities are managed by Dr Dawn Bradley as the Designated Safeguarding Lead (DSL).
• All staff, including psychologists, therapists, and associates, are responsible for adhering to the safeguarding procedures and raising concerns when necessary.
Safeguarding Procedures
We follow a clear safeguarding process to ensure concerns about the safety or well-being of children, young people, or adults at risk are addressed promptly and effectively:
1. Raising Concerns: If a psychologist, therapist, or any staff member identifies a safeguarding issue, they follow the procedures outlined in our Safeguarding Policy, which includes notifying the safeguarding lead and, where necessary, reporting concerns to local authorities or the police.
2. Engagement with Authorities: When appropriate, we refer concerns to the local authority or other relevant services. In cases involving individuals who may pose a risk to vulnerable groups, we may refer the matter to the Disclosure and Barring Service (DBS).
3. Confidentiality: While we aim to protect the confidentiality of our service users, in cases of safeguarding, we may need to disclose personal information to protect an individual or others from harm.
For more detailed information, please refer to our full Safeguarding Policy, available on request or on our website.
Research
At Summit Psychology Services, we engage in different types of research, including Action Research in Education and Discovery Days, a form of action research. All research conducted is voluntary, and we always obtain explicit consent from participants before involving them in any research projects. Participants are provided with detailed information about the nature of the research, how their data will be used, and their right to withdraw at any time.
For academic research that may be published, the same principles apply: participants’ consent is always sought, and they are informed of how their data will be used. The right to withdraw from the research is made clear from the start of participation.
Where possible, participant data is anonymised to protect privacy. However, in certain types of research, participants may be identified (for example, in case studies or specific educational research). In such cases, we will provide clear information to participants and seek their express consent before using identifiable data.
Updates to Our Privacy Policy
This policy may be updated from time to time to reflect changes in law or our practices. Please check our website regularly for the latest version.
If you have any questions about this privacy policy, please contact us at enquiries@summitpsychologyservices.co.uk.
Summit Psychology Services, 15 High Street, Newcastle-Under-Lyme, Staffordshire, ST5 1LG