Introduction

This is Sade Health Limited's Privacy Notice.

As part of the ADHD and Autism assessment services we offer, we are required to process personal data about our staff, our service users and, in some instances, the friends or relatives of our service users and staff. "Processing" can mean collecting, recording, organising, storing, sharing or destroying data.

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We are committed to being transparent about why we need your personal data and what we do with it. This information is set out in this privacy notice. It also explains your rights when it comes to your data.

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Our contact details

Email: hello@wearealtum.ai

Address: 86-90 Paul Street, London EC2A 4NE

Service Users

What data do we have

So that we can provide a safe and professional ADHD and Autism assessment service, we need to keep certain records about you. We may process the following types of data:
•    Your basic details and contact information e.g. your name, address, date of birth, NHS number and next of kin
•    Your financial details e.g. details of how you pay us for your assessment or your funding arrangements
•    Referral information from your GP, school, or other healthcare professionals
•    Assessment questionnaires and screening tools completed by you or your family
•    Communication records including emails, phone calls, and consultation recordings

We also record the following data which is classified as "special category":
•    Health and social care data about you, including both your physical and mental health data, ADHD/Autism assessment results, and clinical diagnoses
•    Educational information including school reports and academic performance data
•    Safeguarding information where there are concerns about your welfare or safety
•    We may also record data about your race, ethnic origin, sexual orientation or religion if relevant to your assessment

Why do we have this data?
We need this data so that we can provide high-quality ADHD and Autism assessment and support services. By law, we need to have a lawful basis for processing your personal data.
We process your data because:
•    We have a contract with you or your commissioner to provide assessment services
•    We have a legal obligation to do so -- generally under the Health and Social Care Act 2012, Mental Capacity Act 2005, or Children Act 1989
•    We have a legitimate interest in providing healthcare services and maintaining clinical records
We process your special category data because:
•    It is necessary for us to provide and manage healthcare services (Article 9(2)(h) GDPR)
•    It is necessary due to social security and social protection law (generally this would be in safeguarding instances)
•    We are required to provide data to our regulator, the Care Quality Commission (CQC), as part of our public interest obligations
•    You have provided explicit consent for specific purposes
 

Common law duty of confidentiality

In our use of health and care information, we satisfy the common law duty of confidentiality because:

• You have provided us with your consent (either implicitly to provide you with care, or explicitly for other uses)

• We have a legal requirement to collect, share and use the data

• The public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with social services for safeguarding purposes)

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Where do we process your data?

So that we can provide you with high quality ADHD and Autism assessment services we need specific data. This is collected from or shared with:

1. You or your legal representative(s)/parents/carers

2. Third parties

We do this via secure online platforms, phone calls, email, post, and digital assessment forms.

Third parties are organisations we might lawfully share your data with. These include:

• Other parts of the health and care system such as your GP, local hospitals, CAMHS services, and other health and care professionals

• Schools, colleges, and educational settings (with your consent)

• Local Authority social services departments

• NHS commissioners and Clinical Commissioning Groups/Integrated Care Boards

• Your family or friends -- with your permission

• Organisations we have a legal obligation to share information with i.e. for safeguarding, the CQC

• The police or other law enforcement agencies if we have to by law or court order

• Multi-agency safeguarding partnerships when required for child or adult protection

National Data Opt Out

We review our data processing on an annual basis to assess if the national data opt-out applies. This is recorded in our Record of Processing Activities. All new processing is assessed to see if the national data opt-out applies.

At this time, we do not share any data for planning or research purposes for which the national data opt-out would apply. We review all of the confidential patient information we process on an annual basis to see if this is used for research and planning purposes. If it is, then individuals can decide to stop their information being shared for this purpose. You can find out more information at https://www.nhs.uk/your-nhs-data-matters/.

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Staff

What data do we have?

So that we can provide a safe and professional service, we need to keep certain records about you. We may record the following types of data:

• Your basic details and contact information e.g. your name, address, date of birth, National Insurance number and next of kin

• Your financial details e.g. details so that we can pay you, insurance, pension and tax details

• Your training records including safeguarding training, clinical competencies, and CPD

• Professional registration details (e.g. HCPC, GMC, NMC registration numbers)

• Performance management and supervision records

We also record the following data which is classified as "special category":

• Health and social care data about you -- we will only collect this if it is necessary for us to know as your employer, e.g. fit notes or in order for you to claim statutory maternity/paternity pay

• We may also, with your permission, record data about your race, ethnic origin, sexual orientation or religion for equality monitoring purposes

As part of your application you will be required to undergo an enhanced Disclosure and Barring Service (DBS) check (Criminal Record Check). We do not keep this data once we've verified your suitability for employment.

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Why do we have this data?

We require this data so that we can contact you, pay you and make sure you receive the training and support you need to perform your job safely in a healthcare setting. By law, we need to have a lawful basis for processing your personal data.

We process your data because:

• We have a legal obligation under UK employment law

• We are required to do so in our performance of a public task (healthcare provision)

• We have a legitimate interest in processing your data for workforce planning and professional development

• We are required to provide data to our regulator, the Care Quality Commission (CQC), as part of our public interest obligations

We process your special category data because it is necessary for us to process requests for sick pay or maternity pay, and for equality monitoring (with your consent).

If we request your criminal records data it is because we have a legal obligation to do this due to the type of work you do with children and vulnerable adults. This is set out in the Data Protection Act 2018 and the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975.

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Friends/Relatives

What data do we have?

As part of our work providing high-quality ADHD and Autism assessment services, it might be necessary that we hold the following information on you:

• Your basic details and contact information e.g. your name and address as emergency contact or next of kin

• Information you provide about the service user's developmental history or behaviour

• Your contact details if you have parental responsibility or lasting power of attorney

Why do we have this data?

We process your data because we have a legitimate business interest in holding next of kin and lasting power of attorney information about the individuals who use our service, and keeping emergency contact details for our staff. For children's assessments, we also need family developmental history information to complete comprehensive assessments.

How do we store your personal information?

Your information is securely stored using encrypted, password-protected systems hosted in UK data centres. We follow strict data security protocols including:

• End-to-end encryption for all data transmission and storage

• Multi-factor authentication for staff access

• Regular security audits and penetration testing

• Access controls based on job roles and clinical need

We retain your information for the time periods specified in the NHS Records Management Code of Practice:

• Adult clinical records: 8 years after last contact

• Children's records: Until age 25 (or 8 years after age 18 if longer)

• Safeguarding records: 25 years minimum

• Staff records: 7 years after employment ends

After the retention period, we will securely dispose of your information by wiping electronic media to government security standards and securely shredding paper records.

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Our Website

In order to provide you with the best experience while using our website and online assessment platform, we process some data about you including:

• IP address and browser information for security and technical purposes

• Cookies for website functionality and user experience

• Form submissions including contact forms and assessment applications

• Usage analytics to improve our services (anonymised where possible)

You can manage your cookie preferences through our cookie settings or your browser controls.

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Your Rights

The data that we keep about you is your data and we ensure that we keep it confidential and that it is used appropriately. You have the following rights when it comes to your data:

1. You have the right to request a copy of all of the data we keep about you. Generally, we will not charge for this service

2. You have the right to ask us to correct any data we have which you believe to be inaccurate or incomplete. You can also request that we restrict all processing of your data while we consider your rectification request

3. You have the right to ask that we erase any of your personal data which is no longer necessary for the purpose we originally collected it for, subject to clinical and legal retention requirements

4. You may also request that we restrict processing if we no longer require your personal data for the original purpose, but you do not wish for it to be erased

5. You can ask for your data to be erased if we have asked for your consent to process your data. You can withdraw consent at any time -- please contact us to do so

6. If we are processing your data as part of our legitimate interests as an organisation or in order to complete a task in the public interest, you have the right to object to that processing. We will restrict all processing of this data while we look into your objection

You may need to provide adequate information for our staff to be able to identify you, for example, a passport or driver's licence. This is to make sure that data is not shared with the wrong person inappropriately. We will always respond to your request as soon as possible and at the latest within one month.

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Healthcare Limitations

Some rights may be limited where exercising them could seriously harm your physical or mental health, someone else's health, or interfere with your clinical care. We will always explain if any exemptions apply to your request and seek to accommodate your request where possible.

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Contact Us and Complaints

If you would like to exercise any of your rights or have questions about this privacy notice, please contact:

General Privacy Enquiries:
Email: hello@wearealtum.ai
Address: Sade Health Limited, 86-90 Paul Street, London EC2A 4NE

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If you would like to complain about how we have dealt with your request, please contact:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Website: https://ico.org.uk/global/contact-us/
Phone: 0303 123 1113