Privacy Policy Statement for The Speech Network

When you use The Speech Network you trust us with your information. This privacy policy is meant to help you understand what data we collect, why we collect it, and what we do with it. We have tried to make it as simple as possible but if you have any questions please contact us

1. Information we collect

The Speech Network & Associates hold personal data as part of conducting a professional service. The data follows under the following headings: healthcare records, clinical records, general administrative records, and financial records.

1.1 Healthcare records

A healthcare record refers to all information collected, processed and held both in manual and electronic formats pertaining to the service user and their care. Speech and language problems can be complex, and a wide range of information may be collected in order to best meet the needs of the client, and to maintain a high quality service which meets best practice requirements. In order to provide a high quality service, a range of information may be collected.

Examples of data collected and held on all current and active clients include the following:

  • Contact details: Name, address, phone numbers, e-mail address,

  • Personal details: Date of birth

  • Other contacts: name and contact details of GP and any other relevant healthcare professionals involved.


1.2 Clinical records

Specific data in relation to communication skills may be collected and held, such as assessment forms, reports, case notes, e-mails, text messages and transcripts of phone. Audio and video files may also be collected and stored.

1.3 Financial records

A financial record pertains to all financial information concerning the practice, e.g. invoices, receipts, information for Revenue. The Speech Network may hold data in relation to: on-line purchasing history, card payments, bank details, receipts and invoices. Information will include name of bill payer, client name, address and record of invoices and payments made.


2. Where we get our information

Personal data will be provided by the client. This information will be collected as part of a case history form prior to, or on the date of first contact.

Information may also be provided directly from relevant third parties such as medical professionals and allied health professionals.

3. How we use the information that we collect

We use the information we collect to provide assessment and therapy as per the relevant professional guidelines, as well as to maintain the general running of the business, such as running our electronic booking system, keeping our accounts and updating you of any changes in policies or fees.

Information may also be used for research and training purposes, but only with the written consent of the client.

3.1 Data retention periods

The retention periods are the suggested time periods for which the records should be held based on the organisation’s needs, legal and/or fiscal precedence or historical purposes. Following the retention deadline, all data will be destroyed under confidential means.

3.2 Client Records

3.2.1 Clinical Records

The Speech Network & Associates keep both physical and electronic records of clinical data in order to provide a service.

  • The preferred format for clinical data is electronic.

  • Clinical data is deleted/confidentially destroyed after 8 years

  • Video records/ voice recordings relating to client care/videoconferencing records may be recorded with consent, analysed and then destroyed. If written consent is provided to use recordings for training purposes, the client will have the option to withdraw consent at any time.

3.2.2 Financial Records

The Speech Network keeps electronic records of financial data from those who use our services.

Section 886 of the Direct Tax Acts states that the Revenue Commissioners require records to be retained for a minimum period of six years after the completion of the transactions, acts or operations to which they relate. These requirements apply to manual and electronic records equally.

  • Financial Data is kept for 6 years to adhere to Revenue guidelines.

  • Financial Data (including non-payment of bills) can be given to Revenue at Revenue’s request.

3.2.3 Contact Data

Contact Data is kept for 6 years to allow processing of Financial Data if required. (This may be retained for longer for safety or a legal request)

3.3 Exceptions

If under investigation or if litigation is likely, files must be held in original form indefinitely, otherwise files are held for the minimum periods set out above.

4. Information we share

We do not share personal information with companies, organisations and individuals outside The Speech Network unless one of the following circumstances apply:

4.1 With your consent:

We will only share your Personal Identifying Information (PII) to third parties when we have express written permission to do so. The Speech Network requires opt-in consent for the sharing of any sensitive information.

Third parties may include: hospitals, GPs, other allied health professionals, educational facilities.

We ask for consent at time of booking your appointment that information will be shared with the relevant associate therapist responsible for your therapy and any other professionals involved in your care.

4.2 For legal reasons:

We will share personal information with companies or organisations outside of The Speech Network if disclosure of the information is reasonably necessary to:

      • Meet any applicable law, regulation, legal process or enforceable governmental request.

      • To protect against harm to the rights, property or safely of The Speech Network our service users or the public as required or permitted by law.

5. How and when we obtain consent

Prior to initial assessment or consultation, consent is obtained for online therapy alongside audio and video recording during the session at the time of booking their appointment. Consent to the 24 hour cancellation policy is additionally obtained.

Optional consent to allow therapists to use recordings for training purposes is also requested.

Should a client wish to withdraw their consent for data to be processed, they can do so by contacting The Speech Network.

6. How we protect your data

In accordance with the General Data Protection Regulation (GDPR), we will endeavour to protect your personal data in a number of ways:

6.1 By limiting the data that we collect in the first instance

All data collected by us will be collected solely for the purposes set out at 1 above and will be collected for specified, explicit and legitimate purposes. The data will not be processed any further in a manner that is incompatible with those purposes save in the special circumstances referred to in section 5.1. Furthermore, all data collected by us will be adequate, relevant and limited to what is necessary in relation to the purposes for which it is collected which include, inter alia, the assessment, diagnosis and treatment of speech, language and communication disorders.

6.2 By transmitting the data in certain specified circumstances only

Data will only be shared and transmitted, be it on paper, electronically only as is required, and as set out in section 3.

6.3 By keeping only the data that is required

When it is required and by limiting its accessibility to any other third parties.

6.4 By disposing of/destroying the data once the individual has ceased receiving treatment

Within 8 years of the completion of this treatment . Where data is required to be held by us for longer than the period of 8 years we will put in place appropriate technical and organisational measures to ensure a level of security appropriate to the risk. These may include measures such as the encryption of electronic devices, pseudonymisation of personal data, and/or safe and secure storage facilities for paper/electronic records.

6.5 By retaining the data for only as long as is required

Which in this case is 8 years except for circumstances in which retention of data is required in circumstances set out at part 1.1 above or in certain specific circumstances as set out at Article 23(1) of the GDPR.

6.6 By destroying the data securely and confidentially after the period of retention has elapsed.

This could include the use of confidential shredding facilities or, if requested by the individual, the return of personal records to the individual.

6.7 By ensuring that any personal data collected and retained is both accurate and up-to-date.

7. Protecting your Rights to Data

7.1Adult clients

Adults have the right to request data held on them as per article 15 of GDPR. A request must be made in writing. Further information regarding accessing your personal data are available in the document ‘Rights of Individuals under the General Data Protection Regulation’, downloadable from: www.gdprandyou.ie

8. Security

The Speech Network as with most providers of healthcare services is aware of the need for privacy. As such, we aim to practice privacy by design as a default approach, and only obtain and retain the information needed to provide you with the best possible service.

All persons working in, and with The Speech Network in a professional capacity are briefed on the proper management, storage and safekeeping of data.

All data used by The Speech Network & Associates including personal data may be retained in any of the following formats:

  1. Electronic Data

  2. Physical Files

The type of format for storing the data is decided based on the format the data exists in.

Where applicable, The Speech Network & Associates may convert physical files to electronic records to allow us to provide a better service to clients.

8.1 Data Security

The Speech Network understands that the personal data used in order to provide a service belongs to the individuals involved. The following outlines the steps which The Speech Network & Associates use to ensure that the data is kept safe.

8.1.1 Electronic Data

All electronic data is contained in the following systems :

  • email system

  • encrypted hard drives

  • online acuity booking system (cloud based)

8.1.2 Physical Files

- These records are kept in a container secured with a lock and key.

8.2 Security Policy

8.2.1 All persons working in The Speech Network are aware and briefed on and refresh the requirements for good data hygiene. This briefing compliance is monitored by the The Speech Network data controller and includes, but is not limited to:

      • Awareness of client conversations in unsecure locations.

      • Enabling auto-lock on devices when leaving them unattended.

      • Use of non-identifiable note taking options. (initials, not names).

      • The awareness of The Speech Network procedure should a possible data breach occur, either through malicious (theft) or accident (loss) of devices or physical files.