Data Protection and Information Governance Policy
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2. Legislative and Regulatory Framework
Draig Behaviour Consultancy processes personal data in accordance with the following legislation and professional standards:
UK General Data Protection Regulation (UK GDPR)
Data Protection Act 2018
Human Rights Act 1998 (Article 8 – Right to respect for private and family life)
Common Law Duty of Confidentiality
Health and Social Care (Quality and Safety) Regulations 2020 (where applicable to commissioned services)
Records Management Code of Practice for Health and Social Care (where applicable)
Safeguarding Vulnerable Groups Act 2006 (where relevant to service delivery)
This policy is underpinned by the UK GDPR principles set out in Article 5, and all processing of personal and special category data is carried out in accordance with these principles and associated legal obligations.
3. Purpose of This Policy
The purpose of this policy is to ensure that Draig Behaviour Consultancy processes personal data lawfully, fairly, transparently and securely when delivering behavioural consultancy services to residential care providers and associated organisations.
This includes ensuring compliance with statutory obligations, safeguarding individuals, and maintaining public trust in the handling of highly sensitive behavioural and health-related information.
4. Scope
This policy applies to:
The Director of Draig Behaviour Consultancy
Any associates, subcontractors or consultants engaged by the organisation
Any third parties processing data on behalf of the organisation
It applies to all personal data processed in both electronic and paper formats.
4. Data Protection Principles (Article 5 UK GDPR)
Draig Behaviour Consultancy complies with the six core principles of data protection:
Lawfulness, fairness and transparency (Art. 5(1)(a))
Purpose limitation (Art. 5(1)(b))
Data minimisation (Art. 5(1)(c))
Accuracy (Art. 5(1)(d))
Storage limitation (Art. 5(1)(e))
Integrity and confidentiality (Art. 5(1)(f))
The organisation also recognises its accountability obligation under Article 5(2), requiring evidence of compliance through documented policies, audits and governance controls.
5. Data Protection Governance and Responsibility
Draig Behaviour Consultancy operates a sole-director governance model.
The Director acts as the organisation’s Data Protection Officer (DPO) for operational purposes, with responsibility for:
Compliance with UK GDPR and the Data Protection Act 2018
Oversight of all data processing activities
Implementation of technical and organisational security measures
Monitoring compliance through monthly audits
Acting as the primary contact for data protection matters
This role reflects the size and structure of the organisation and ensures proportional governance in line with UK GDPR requirements.
6. Lawful Basis for Processing (Articles 6 & 9 UK GDPR)
Personal data is only processed where a lawful basis under Article 6 applies. In most cases, Draig Behaviour Consultancy processes data under:
Article 6(1)(b): Performance of a contract
Article 6(1)(c): Legal obligation
Article 6(1)(e): Public task (where acting on behalf of public sector commissioners)
Article 6(1)(f): Legitimate interests (service delivery and safeguarding)
Where special category data is processed (e.g. behavioural, health or disability-related information), an additional condition under Article 9 is applied, including:
Article 9(2)(h): Provision of health or social care or treatment
Article 9(2)(g): Substantial public interest (safeguarding and social care provision, Schedule 1 Data Protection Act 2018)
All special category processing is subject to an appropriate Schedule 1 condition and supporting documentation where required.
7. Types of Information Processed
Draig Behaviour Consultancy processes only the minimum data necessary to deliver safe and effective behavioural consultancy services.
This includes:
7.1 Client and Service User Information
Behavioural assessments and analysis
Positive Behaviour Support (PBS) plans
Incident and restraint records
Risk assessments
Care plans
Social services records of involvement and Case overviews
Statutory documents, including Deprivation of Liberty Orders
Assessment reports and records of involvement from other professionals
Health and diagnostic information (special category data)
7. 2 Professional and Organisational Information
Care provider staff details
NHS or local authority professional contact information
Commissioning documentation
Meeting notes and service correspondence
7.3 Business and Administrative Data
Contracts and service agreements
Invoices and financial records
Email correspondence
Supplier information
8. Data Collection and Minimisation
Data is obtained directly from:
Residential care providers
Local authority commissioners
Healthcare professionals
Family members
Direct behavioural observation and assessment
In accordance with Article 5(1)(c) UK GDPR (data minimisation), only data relevant and necessary for behavioural consultancy is collected. Unnecessary or excessive data is not retained or processed.
9. Information Use and Purpose Limitation
In accordance with Article 5(1)(b), data is only used for specified and legitimate purposes, including:
Delivery of behavioural consultancy services
Development of Behaviour Support Plans and interventions
Risk assessment and safeguarding support
Professional communication with care teams
Service evaluation and monitoring outcomes
Compliance with contractual and legal obligations
Data is not reused for unrelated purposes without further lawful basis.
10. Data Storage and Security (Article 32 UK GDPR)
Draig Behaviour Consultancy implements appropriate technical and organisational measures in line with Article 32 UK GDPR, including:
Microsoft OneDrive for Business cloud storage with encryption in transit and at rest
Multi-factor authentication for all system access
Role-based access controls restricting data to authorised users only
Password-protected devices
Regular software updates and antivirus protection
Secure disposal of digital and paper records
Monthly information governance audits are conducted to review access permissions, monitor system activity logs (where available), and confirm that no unauthorised access has occurred.
Cyber liability insurance is maintained to support organisational resilience and incident response.
11. Data Retention (Storage Limitation Principle)
In accordance with Article 5(1)(e), personal data is retained only for as long as necessary for the purposes for which it was collected.
Retention periods are determined based on:
Legal and regulatory requirements
Safeguarding considerations
Contractual obligations with commissioners
Typical retention periods include:
Client behavioural records: 8 years post-service (or longer if safeguarding requires)
Financial records: 6 years
Contractual documentation: 6 years
Associate records: 6 years
Records are securely destroyed using appropriate deletion or shredding methods.
12. Data Subject Rights (Articles 12–23 UK GDPR)
Individuals have the following rights under UK GDPR:
Right to be informed (Articles 12–14)
Right of access (Article 15)
Right to rectification (Article 16)
Right to erasure (Article 17)
Right to restrict processing (Article 18)
Right to data portability (Article 20)
Right to object (Article 21)
Rights relating to automated decision-making (Article 22)
Requests are managed by the Data Protection Officer and responded to within one calendar month unless legally extended.
13. Data Breach Management (Articles 33 & 34 UK GDPR)
All data breaches are reported immediately to the Data Protection Officer.
In accordance with:
Article 33, notifiable breaches are reported to the Information Commissioner’s Office within 72 hours where required
Article 34, affected individuals are notified without undue delay where there is a high risk to rights and freedoms
All breaches are recorded in an internal incident log, including root cause analysis and corrective actions.
14. Sharing of Information
Information is shared only where lawful, necessary and proportionate.
Recipients may include:
Residential care providers
Local authorities
NHS professionals
Safeguarding teams
Commissioners
Legal or regulatory bodies (where required by law)
No personal data is sold or used for marketing purposes.
15. Confidentiality and Professional Standards
All individuals working on behalf of Draig Behaviour Consultancy are bound by:
Confidentiality obligations under common law
Professional ethical standards relevant to behaviour analysis practice
Contractual confidentiality clauses
Confidentiality is maintained at all times unless there is a lawful safeguarding or legal disclosure requirement.
16. Data Protection by Design and Default (Article 25 UK GDPR)
The organisation applies data protection principles at the earliest stage of any new process, ensuring:
Minimal data collection
Access restriction by default
Secure system configuration
Privacy considerations embedded into service design
17. Electronic Communications
Electronic communication is managed securely:
Sensitive data is encrypted prior to emailing, with the password sent in a separate email in case of interception
Emails are restricted to necessary recipients
Files are shared via secure OneDrive links with access control
Devices are password protected and encrypted where possible
18. Training and Competence
The Director maintains ongoing awareness of UK GDPR obligations through professional development, guidance updates, and sector-specific information governance resources relevant to social care and behavioural consultancy.
19. Monitoring, Audit and Accountability
Draig Behaviour Consultancy maintains a documented audit cycle including:
Monthly access control reviews
Cloud storage security checks
Review of data processing activities
Review of incident logs and corrective actions
This supports compliance with the accountability principle (Article 5(2)).
20. Complaints and Regulatory Oversight
Complaints relating to data protection are handled internally in the first instance.
Individuals also retain the right to complain to the Information Commissioner’s Office (ICO).
21. Policy Review
This policy is reviewed annually or sooner where:
Legislative or regulatory changes occur
A significant data breach occurs
Service delivery changes materially affect data processing