Privacy Policy – Communication Pathways Speech and Language Therapy Ltd
1. Who we are
Communication Pathways Speech and Language Therapy Ltd is an independent speech and language therapy practice. We are the data controller for the personal information described in this policy, which means we decide how and why it is used.
This policy explains what we collect, why, how long we keep it and what rights you have. It covers our website [website address], enquiries made to us, the therapy services we provide, and expert reports we prepare for legal proceedings.
We follow the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Our speech and language therapists are registered with the Health and Care Professions Council (HCPC) and follow its standards on confidentiality.
| Company name |
Communication Pathways Speech and Language Therapy Ltd |
| Company number |
16523467 |
| ICO registration number |
ICO: 00015576994 |
| Data protection contact |
Rowan Ranner |
2. Information we collect
What we hold depends on how you deal with us.
| Who you are |
What we may collect |
| Website visitor |
IP address, browser and device type, pages visited, date and time of visit, referring page |
| Someone making an enquiry |
Name, contact details, the reason for your enquiry and anything you choose to tell us |
| Client (or parent/carer of a client) |
Name, date of birth, address, contact details, GP and school or nursery details, medical and developmental history, assessment results, session notes, reports, recordings made, images created with consent, and correspondence |
| Professionals we work with |
Allied health professionals (AHP’s), medical, legal professionals, professionals from statutory services and third sector organisations. |
| Person assessed for a medico-legal report |
Identity details, medical records, witness statements and other documents supplied by instructing solicitors, assessment results and the report itself |
| Paying party |
Billing name, address and invoice records (we do not store card details) |
Some of this is special category data, such as information about health, development, disability and communication needs. We take extra care with it, as explained below.
We receive information directly from you, and sometimes from others with your knowledge, such as GPs, hospitals, schools, local authorities, case managers, insurers and solicitors.
3. How we use your information and our lawful basis
The law requires us to have a lawful basis for each use of personal data, and an extra condition for special category data.
| Purpose |
Lawful basis (Article 6) |
Condition for health data (Article 9) |
| Replying to enquiries |
Legitimate interests |
Explicit consent, if you share health details |
| Assessment, therapy and reports for clients |
Contract with you or the person paying |
Provision of health care (Art. 9(2)(h)) |
| Sharing with schools or other professionals involved in care |
Contract or legitimate interests |
Provision of health care, with your agreement |
| Preparing medico-legal expert reports |
Legitimate interests |
Legal claims (Art. 9(2)(f)) |
| Invoicing and accounts |
Contract and legal obligation |
Not applicable |
| Keeping records and meeting HCPC and insurance requirements |
Legal obligation and legitimate interests |
Provision of health care and legal claims |
| Recording sessions for clinical use |
Consent |
Explicit consent |
| Running and improving our website |
Legitimate interests |
Not applicable |
Where we rely on consent, you can withdraw it at any time. This does not affect anything we did before you withdrew it.
We do not sell your information, use it for marketing without your consent, or make decisions about you by automated means.
4. Children and young people
Many of our clients are children. We usually collect their information from a parent or person with parental responsibility.
We involve children in decisions about their care in a way that suits their age and understanding. A young person who is able to understand their rights may make requests about their own information, and we will take their views into account.
Our website is not aimed at children, and we do not knowingly collect information online from anyone under 16. If you think a child has sent us information through the website, please contact us and we will delete it.
5. Sharing, storage and security
We share information only when it is needed and lawful. This may include:
- professionals involved in a client’s care, such as GPs, consultants, schools, nurseries, case managers and allied health professionals, normally with your agreement
- the person or organisation paying for therapy, such as a solicitor, insurer, case manager or local authority, limited to what they need
- solicitors, courts and other parties in legal proceedings, where we are instructed as an expert
- our clinical supervisor, using anonymised information wherever possible
- service providers who support us, such as secure clinical records, email, IT and accounting providers, under written contracts that protect your data
- regulators, our professional indemnity insurer, or the police and safeguarding services where the law requires it or someone is at risk of harm
We keep records on secure, password-protected systems with access limited to people who need it. Paper records are kept locked and are shredded securely when no longer needed.
6. AI ambient voice technology
We may use AI ambient voice technology (AVT) to help write clinical notes and meeting records. AVT listens to a conversation and produces a transcript or draft summary, so the therapist can focus on you rather than on typing.
The tool we use is Heidi, provided by Heidi Health. It is a service provider acting on our instructions under a written data processing agreement.
In clinical sessions, we only use AVT with consent.
- We will ask you, or a parent or carer for a child, before the session starts.
- We will explain what the tool does and what happens to the recording.
- You can say no, or ask us to stop at any time. This will not affect your care.
- We will take children’s views into account in a way that suits their age and understanding.
In meetings, we are open about using AVT.
This includes multidisciplinary meetings, therapy planning meetings, case conferences, and meetings with case managers or solicitors. We will tell everyone at the start that AVT is in use and why. If anyone objects, we will switch it off and take notes by hand.
How we keep it safe
- The therapist checks and edits every transcript and summary before it is saved. AVT does not make clinical decisions. Responsibility for AVT outputs cannot be delegated to the tool or its supplier: the speech and language therapist keeps full responsibility and accountability for every note, record and decision.
- Only the checked note is kept in your clinical record. Audio and draft transcripts are deleted within 30 days.
- Data is stored in UK, and the supplier does not use your information to train its AI models.
Our lawful basis is the same as for the rest of your care: our contract with you, with the health care condition for health data. For clinical sessions we also rely on your consent to record.
7. How long we keep information
We keep information only as long as we need it, guided by RCSLT guidance.
| Record |
How long we keep it |
| Clinical records for children |
Until the client’s 25th birthday, or 26th if they were 17 when treatment ended |
| Clinical records for adults |
8 years after treatment ends |
| Medico-legal case files and reports |
[6] years after the case concludes, or longer if the instructing party or court requires |
| Invoices and financial records |
6 years after the end of the financial year, as required by HMRC |
| Enquiries that do not lead to therapy |
12 months |
8. Cookies and our website
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
9. Your rights and how to contact us
Under UK data protection law you have the right to:
- ask for a copy of the information we hold about you
- ask us to correct information that is wrong or incomplete
- ask us to delete information, where we no longer have a reason to keep it
- ask us to restrict how we use your information
- object to our use of your information where we rely on legitimate interests
- ask for information you gave us to be passed to another provider, where this applies
- withdraw consent at any time, where we rely on consent
Some rights have limits. For example, we may need to keep clinical records for the periods above, and information in legal proceedings may be subject to legal privilege or court rules.
To make a request, contact Rowan Ranner at rowanrannerslt@outlook.com or 07495 532 943. We will respond within one month and do not normally charge a fee. We may ask for proof of identity first.
If you are unhappy with how we have handled your information, please tell us first so we can try to put it right. You can also complain to the Information Commissioner’s Office at ico.org.uk or on 0303 123 1113.
We review this policy regularly. The latest version will always be on our website.
Last updated: October 2026
