At 'D-Restricted: Specialist Infant Feeding Support' I take your privacy very seriously. I will only ever use your information for admin purposes for your infant’s case, and continuity of care. This is in order to provide accurate treatment and care to the parent-baby dyad; that you have sought from me.
Your information is NOT stored online, and is NOT passed on to third parties, and I do NOT subscribe you to mailing lists.
At your appointment, you will be asked to sign to say that you agree to this 'Privacy Notice' as set out below:
This privacy notice only covers'D-Restricted:Specialist Infant Feeding Support' (www.tongue-tie.info and www.d-restricted.com). It does not cover all sites that can be linked/accessed to via this site, so you should always be aware when you are moving to another site to read the privacy statement on that site too. This includes if I were to recommend a site to read for your information only, which I may send you via email or text, but also if you choose to 'like' or join any related social media pages, such as my facebook support group https://www.facebook.com/groups/219881955258950/.
Should you choose to leave feedback on my website, only your first name/username is displayed alongside your comment and star rating.
The Data Protection Act (1998)
The GDPR (General Data Protection Regulations) enhances and replaces the current Data Protection Regulations as of 25/05/2018. Anyone who holds personal data of any EU citizen through personal identifiable records and mailing lists are obliged to comply.
Under the Data Protection Act (1998) I have a legal duty to protect any information I hold about you. I use leading technologies and encryption software to safeguard your personal information and keep strict security standards to prevent any unauthorised access to it.
I DO NOT pass your details on to any third parties. There are 2 exceptions to this:
Your GP needs to be informed of any treatment/procedure undertaken. Minimal identifiable data is included on this letter and'D-Restricted:Specialist Infant Feeding Support' currently uses Royal Mail post to send this to them. If during your consultation I suspect additional minor health factors I may include this on the GP letter too.
Should I have concerns relating to the welfare of an infant or adult I believe to be "at risk" to self or others, safeguarding concerns or health complications out of my sphere of practice, I may contact other professionals for additional intervention, thus breaching confidentiality. This may include the GP, Health Visitor, Social Worker or Police.
How will 'D-Restricted:Specialist Infant Feeding Support' use the information held against me?
To provide continuation of care by myself only, through assessment, treatment and support, as appropriate throughout your feeding journey for you and your infant.
In order to care for/be accountable to the parent-infant dyad, it is necessary for 'D-Restricted:Specialist Infant Feeding Support' to hold your personal information, but it is also a legal requirement for me to do so as recognised by the NMC (Nursing and Midwifery Council) who stipulate that records are to be kept for 25 years post last contact made. After the 25 years has passed, the records are securely destroyed (cross-shredded, erased, or burnt etc).
I may use your infant's information, anonolysed, without notice; for auditing or research purposes.
Online submission of personal information
This website is powered by Wix (www.wix.com). The online submission of your details when booking or contacting me are sent via Wix (the Data Processor) to myself (the Data Controller)-for both booking and appointment, or completing feedback. Please note that Wix.com is certified under the EU-US Privacy Shield Framework and the Swiss-US privacy shield framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union to the United States, and therefore adheres to the Privacy Shield Principles. Their platform also claims to be compliant to the new GDPR regulations from May 2018.
All merchants, regardless of the size of their company who process card payments have to comply with PCI DSS.
Your online deposit is processed through 'Stripe' (card payment processor) who are compliant in this instance as your card payment details are not visible to me. Further information from them is found here: https://stripe.com/docs/security
For telephone deposits and card payments via the card terminal, I pay additional fees to ensure your data safety. Should you have concerns re fraud or card data use since using your card details, you are encouraged to contact your card provider immediately. The Information security policy is available to view at the clinic, or I can email it to you if requested.
What information do you hold about me/my child?
The records that have been made at your assessment appointment, treatment/procedural appointment, and any written follow ups/notes made. These have been made in conjunction with the parent(s).
There is also a CCTV camera to the front and rear of the property: which captures images of you entering the building and the immediate vicinity. Images are stored for 30 days before deletion. This is registered with and complies with the regulations as set by ICO #C8004862.
I take 'before' and 'after' photographs as a visual aid for documentation, and is of your infant's mouth area only. Photographs are taken with your knowledge, and may be utilised for training, online publication (website and facebook group) or related demonstration purposes only and will only be done so with your signed consent/agreement.
Please note that if you are to send photographs/videos to my phone/other devices (text, whatsapp!, messenger, email etc) to observe feeding behaviours during the aftercare period these photos are automatically saved to my phone. I am the only person who uses this phone and it is both fingerprint and password protected should it be mislaid, these photos are saved to your infant's records. I periodically delete photos that have been saved to my devices for privacy purposes. These photos are not used elsewhere.
If you would like a copy of your records please just ask me! I can print this off for you at your appointment, or we can arrange a time for you to collect them from me. Emailing or posting documentation/records is not a secure way to transfer and protect your personal sensitive information.
Your records will be available to you, free of charge, within 10 working days of the request being received. Upon receipt of receiving the record I will require identification (child’s red health care book, NHS number, Proof of address, date of birth) and a signature to say you have received it.
As I have to hold your records for 25 years post contact, if you wanted a copy of that record you can still do so. If in the event I have died, measures are in place to allow you to still access your records. You would need to contact the ICO to trace the appointed data controller: stating business name: ‘Infant Tongue Tie Division Services’ and Membership number: ZA100466. That will give you the details of who to contact.
What if D.Warren is unable to fulfill the appointment(s)?
In the event that D.Warren is ill, I will inform you of this as soon as I am able. A full refund of your deposit will be made so you may be able to arrange another appointment with another practitioner as soon as possible (www.tongue-tie.org.uk/find-a-practitioner).
In the event of sudden serious illness where I would be unable to contact you, or in the event of my death, all appointments would be cancelled by a third party (also healthcare professional who is DBS checked) and arrange a refund as able. Of course the nominated person will need to gain access to your name, telephone number and payment details in order to do so and access to this is protected so may take a while for them to access this information legally. The Association of Tongue-Tie Practitioners (ATP) would be made aware to remove my name from their approved listings, and notices would be put on both my website and social media pages. Patient records will see be available should you wish to view them for 25 years post division. If I have died, Please contact ICO (details below) for details of my successor who will be able to arrange this for you ensuring you can provide the required formal identification.
Your right to withdraw
Until you have achieved your infant feeding goals, I like to contact you periodically to assist/guide/support you through this. This maybe through signposting you to information and alternative websites via text or email, or a service review. Once you are happy and discharged from my care, I am obliged by law to hold your records for a further 25 years.
You may 'opt-out' of any follow-up texts/support at any point.
Should you wish to withdraw from future correspondence regarding the feeding related care of your child you may do so at any point. Either inform me at your appointment that you wish no further contact, or in response to the correspondence I give you.
How are my records stored?
Active records (from point of initial contact up until formal date of agreed discharge) are held on my personal electronic device (iOS), and also a NAS 'home cloud' device. This is password protected with additional fingerprint recognition to access emails.
Once discharged, your record is transferred to an external storage device, which is also encrypted/password protected, and the NAS 'home cloud' document is updated, and the file is securely deleted from my iOS device. This is so that there is always a minimum of 2 copies in my possession. This allows for a second back-up copy at all times.
Both active and dormant records are held in a locked safe, which is stored in a locked cabinet, in a locked clinic room. The clinic room has both a motion sensor burglar alarm and the external building also houses CCTV camera. I also have business level anti-virus/spyware Protection too.
I wish to make a Data Protection related complaint
The ICO (information Commissioner’s Office) is the regulator of the GDPR (General Data Protection Regulations) and complaints should be forwarded to them if it is related to a breech in data collection or record keeping. 'D-Restricted:Specialist Infant Feeding Support' is registered with ICO, Membership number ZA100466. www.ico.org,uk , telephone: 0303 123 1113
Information Commissioner’s Office,
If you have any questions about these terms and conditions, or the practises of 'D-Restricted:Specialist Infant Feeding Support' please contact me in writing at:
31 Avondale Road, Barlestone, Nuneaton, Warwickshire CV13 0HX,
or email email@example.com.
© DIANA WARREN IBCLC, RGN