Privacy Notice: Recording and Transcription of Service User Interactions

A Service User Interaction includes, but is not limited to:

• Brain in Hand Customer Support Team – emails, calls and SMS texts with service users when supporting them with referral, order, purchase, registration, and software issue, as well as any other customer support scenario (e.g., subscription renewals, complaints, technical difficulties, feedback)
• Specialist Support – emails, calls, SMS texts, Session Support Records (SSRs), copying and recordings of sessions whilst arranging or delivering a service user’s support sessions with a Brain in Hand Specialist
• Response Services – emails, call recordings, SMS texts and review records whilst responding to a Traffic Light notification or whilst arranging or conducting a review
• Brain in Hand development team – emails, calls, video, and SMS texts with service users when undertaking product development and user testing.

Please note that these interactions may be with a Brain in Hand employee, or with a third party contracted by Brain in Hand to deliver support.

Brain in Hand takes its data protection obligations very seriously.

There may be times when service user interactions are recorded by Brain in Hand and/or third parties.

Access to personal information, including recordings is limited to only those who need access for purposes agreed with the service user, or where otherwise allowed by law. Access will be permitted to the customer support team, specialist support, and response services.

The legal basis for processing the data is that it is necessary for us to do so in order to fulfil the contract we have with the service user.

The categories of personal information held in relation to service users include contact information, their personal session plans, goals, and strategies.

Brain in Hand may record video or audio of interactions for the following purposes:

• At the request of the service user
• To provide a digital chaperone (for example, where required for a service user under the age of 18)
• To support participant accessibility where agreed
• To support specific situations that require a recorded session, for example at the request of the purchaser or supporter
• Internal training, quality assurance or monitoring of Brain in Hand staff and contractors.

Brain in Hand may also create written transcriptions of interactions for the above purposes. Transcriptions will be created, stored, and processed with the same confidentiality considerations as apply to any other service user information.

There are situations in which Brain in Hand would not find it acceptable to record interactions, even where they may be included in the general purposes as above; for example, if the Service User does not consent to the recording taking place. In this circumstance, it may be required that an additional member of Brain in Hand staff observe the session instead (such as where a chaperone is necessary).

Any personal data that we collect from a service user (whether submitted directly or collected through their use of our system) will be reviewed on a regular basis to ensure that we only continue to store and process it under lawful grounds and for an appropriate time period.

Data collected will be stored for up to 2 years after a user terminates their use of our services for the purpose of being able to reactivate the licence if needed, or in order to respond to any complaints or queries that may arise. After this time, data provided through system use may be held indefinitely in an aggregated and anonymised format to assist us in compiling usage information which helps to inform quality assurance, internal training and monitoring purposes.

No personal information is shared by Brain in Hand with any other third- party organisation, other than where it is necessary for the provision of a service the service user has agreed to. For the provision of the service, personal information will incorporate Brain in Hand Specialist Support and our Response Services such as emails, telephone calls, telephone recording, session video/meeting recording SMS texts, and session support records.

Brain in Hand commits that we:

• Will not share personal data with any third parties without consent from the service user
• Will not use personal data for marketing/publicity etc. without consent from the service user
• Will not share any personal data on any social media platforms without consent from the service user.

The service user must not share any recordings, documents, software, or personal data contained within Brain in Hand on any social media platforms without the prior consent of Brain in Hand.

You can contact DPO@braininhand.co.uk if you have any questions. You can also contact the Information Commissioners' Office in relation to any concerns or issue you may have with the processing of your personal information.