Policies

Speech Therapy HQ

Health and Safety Policy

1. Policy Statement

We are committed to ensuring the health, safety, and welfare of all employees, clients, visitors, and others who may be affected by our activities. We comply with the Health and Safety at Work etc Act 1974 and all relevant regulations. Our aim is to provide a safe and healthy working environment and to prevent accidents and work-related ill health.

2. Responsibilities

Business Owner/Employer:
Has overall responsibility for health and safety, including ensuring this policy is implemented, reviewed, and communicated to all staff

All Staff:
Must take reasonable care of their own health and safety and that of others, cooperate with health and safety arrangements, and report hazards or incidents promptly

3. Risk Assessment

We conduct regular risk assessments for all work activities, and all staff are encouraged to raise concerns if they become aware of a new or change to an activity that may require a new risk assessment.

Control measures are put in place to manage identified risks, and assessments are reviewed annually or after significant changes

4. Safe Working Practices

All staff are provided with appropriate training on safe working methods, including manual handling, infection control, and lone working. Affiliate contractors are responsible for attaining their own mandatory training but are able to access support within Speech Therapy HQ, as required.

Personal protective equipment (PPE) is supplied for staff, or self-provided by Affiliate contractors and must be used as required

Safe environments are established for all therapy sessions, whether in clinics, schools, homes, or online.

5. Accident and Incident Reporting

All accidents, incidents, and near-misses must be reported to the business owner immediately.

Records are maintained, and serious incidents are reported to the Health and Safety Executive (HSE) as required by law

6. First Aid

Adequate first aid arrangements are in place for all work settings. Lone workers are responsible for their own first aid when in the community and are advised to used public services as required.

Staff are informed of the location of first aid supplies and emergency procedures.

7. Information, Instruction, and Training

Health and safety information is provided to all staff, including updates on relevant legislation and guidance. Affiliate contractors are responsible for their own training.

Regular training is provided and recorded, including induction for new staff and updates as required.

8. Consultation

Staff are consulted on health and safety matters, and their feedback is encouraged to improve safety practices.

9. Workplace Facilities

Suitable welfare facilities (toilets, washing, drinking water) are provided at all permanent workplaces.

When working off-site, arrangements are made to ensure access to necessary facilities.

10. Policy Review

This policy is reviewed annually or following significant changes in legislation or business practices.

Signed:
Eve Ferguson

Director

07.11.25

Speech Therapy HQ

Adult Safeguarding Policy

The policy is based on national guidance and The Care Act 2014

Introduction:

This policy is to make sure that Speech Therapy HQ has all the right things in place to

protect and safeguard adults.

Speech Therapy HQ believes in protecting an adult’s right to live in safety, free from abuse

and neglect. This policy sets out the roles and responsibilities of Speech Therapy HQ in

working together in promoting the adult’s welfare and safeguarding them from abuse and

neglect. Employees, trustees and volunteers should be made aware of how this policy can

be accessed.

This policy and related procedures are applicable to all staff, employees and volunteers of

Speech Therapy HQ and any students . Failure to comply with the policy and related

procedures will be addressed without delay and may ultimately result in dismissal/exclusion

from the organisation.

Care Act 2014 Definition of an Adult at Risk of Abuse:

Where a local authority has reasonable cause to suspect that an adult in its area (whether or

not ordinarily resident there)

(a) has needs for care and support (whether or not the authority is meeting any of those

needs),

(b) is experiencing, or is at risk of, abuse or neglect, and

neglect or the risk of it.

Key Principles of Adult Safeguarding:

In the safeguarding of adults, Speech Therapy HQ are guided by the six key principles set

out in The Care Act 2014 and Making Safeguarding Personal. Speech Therapy HQ aims to

demonstrate and promote these six principles in our work:

 Empowerment – People being supported and encouraged to make their own

decisions and informed consent

 Prevention – It is better to take action before harm occurs.

 Proportionality – The least intrusive response appropriate to the risk presented.

 Protection – Support and representation for those in greatest need.

 Partnership – Local solutions through services working with their communities.

Communities have a part to play in preventing, detecting and reporting neglect

and abuse.

 Accountability – Accountability and transparency in delivering safeguarding.

Recognising the signs of abuse:

All staff, employees, volunteers and students are well-placed to identify abuse the adult may

say or do things that let you know something is wrong. It may come in the form of a

disclosure, complaint, or an expression of concern. Everyone within the organisation should

understand what to do, and where to go to get help, support and advice.

Types of Abuse:

The Care Act 2014 defines the following ten areas of abuse. Our safeguarding policy also

includes self-neglect as an additional category. These are not exhaustive but are a guide to

behaviour that may lead to a safeguarding enquiry. This includes:

 Physical abuse - Including assault, hitting, slapping, pushing, misuse of medication,

restraint or inappropriate physical sanctions.

 Domestic Violence/ Domestic Abuse - Including psychological, physical, sexual,

financial, emotional abuse; so called ‘honour’ based violence.

 Exploitation- Including sexual and/or criminal exploitation

 Sexual abuse - Including rape, indecent exposure, sexual harassment, inappropriate

looking or touching, sexual teasing or innuendo, sexual photography, subjection to

pornography. Witnessing sexual acts, indecent exposure and sexual assault or

sexual acts to which the adult has not consented or was pressured into consenting.

 Psychological abuse - Including emotional abuse, threats of harm or abandonment,

deprivation of contact, humiliation, blaming, controlling, intimidation, coercion,

harassment, verbal abuse, cyber bullying, isolation or unreasonable and unjustified

withdrawal of services or supportive networks.

 Financial or material abuse - Including theft, fraud, internet scamming, coercion in

relation to an adult’s financial affairs or arrangements, including in connection with

wills, property, inheritance or financial transactions, or the misuse of misappropriation

of property, possessions or benefits.

 Modern slavery - Encompasses slavery, human trafficking, forced labour and

domestic servitude. Traffickers and those who coerce, deceive and force individuals

into a life of abuse, servitude and inhumane treatment.

 Discriminatory abuse - Including forms of harassment, slurs or similar treatment

because you are, or are perceived to be different due to race, gender and gender

identity, age, disability, sexual orientation or religion.

 Organisational abuse - Including neglect and poor care practice within an institution

or specific care setting such as a hospital or care home, for example or in relation to

care provided in one’s own home. This may range from one off incidents to long-term

ill treatment. It can be through neglect or poor professional practice as a result of the

structure, policies, processes or practices within an organisation.

 Neglect and acts of omission - Including ignoring medical, emotional or physical

care needs, failure to provide access to appropriate health, care and support or

educational services, the withholding of the necessities of life, such as medication,

adequate nutrition and heating.

 Self-neglect - This covers a wide range of behaviour neglecting to care for one’s

personal hygiene, health or surroundings and includes behaviour such as hoarding.

Radicalisation to Terrorism:

The Government through its PREVENT programme has highlighted how some adults may be

vulnerable to exploitation and radicalisation and involvement in terrorism. Signs and

indicators of radicalisation may include:

 Being in contact with extremist recruiters.

 Articulating support for violent extremist causes or leaders.

 Accessing violent extremist websites, especially those with a social networking

element.

 Possessing violent extremist literature.

 Using extremist narratives to explain personal disadvantage.

 Justifying the use of violence to solve societal issues.

 Joining extremist organisations.

 Significant changes to appearance and/or behaviour.

Reporting Concerns:

Any staff member, employee, volunteer or student who becomes aware that an adult is or is

at risk of, being abused must raise the matter immediately with their supervisor /or with the

organisation’s designated safeguarding person. If the adult requires immediate protection

from harm, contact the police and Adult Social Care.

Early sharing of information is the key to providing an effective response where there are

emerging concerns. To ensure effective safeguarding arrangements no one should assume

that someone else will do it.

Safe Recruitment & Selection:

Speech Therapy HQ is committed to safe employment and safe recruitment practices, that

reduce the risk of harm to adults with care and support needs from people unsuitable to work

with them.

Speech Therapy HQ has procedures that cover the recruitment of all staff, employees and

volunteers. All staff are required to have Enhanced Disclosure and Barring Service (DBS)

checks and maintain mandatory training including safeguarding training.

Social Media:

All employees and volunteers should be aware of Speech Therapy HQ social media policy

and procedures (Acceptable Use of Technology Policy) and the code of conduct for

behaviour towards the adults and children we support.

Is there a Person in a Position of Trust Involved?

In any instance of safeguarding, consideration must be given as to whether an allegation has

been made against a person in a position of trust (PiPoT) and who may be a risk to others.

This can be anyone from a formal employee or volunteer, to an informal carer. If you are

concerned about the welfare of others, contact Adut Social Care and the Police.

Training and Awareness:

Speech Therapy HQ will ensure an appropriate level of safeguarding training is available to

its Employees and Volunteers. Affiliate contractors are responsible for maintaining their own

safeguarding training as part of their own professional registration.

For all employees who are working or volunteering with adults at risk this requires them as a

minimum to have awareness training that enables them to:

 Understand what safeguarding is and their role in Safeguarding Adults.

 Recognise an adult potential in need of safeguarding and take action.

 Understand how to report a safeguarding Alert.

 Understand dignity and respect when working with individuals.

 Have knowledge of the Safeguarding Adults Policy.

Similarly, employees and volunteers may encounter concerns about the safety and wellbeing

of children/young people. For more information about children’s safeguarding, refer to

Speech Therapy HQ Children and Young People’s Safeguarding Policy.

Mental Capacity:

The MCA defines someone is lacking capacity, because of an illness or disability such as a

mental health problem, dementia or a learning disability, who cannot do one or more of the

following four things:

 Understand information given to them about a particular decision

 Retain that information long enough to be able to make the decision

 Weigh up the information available to make the decision

 Communicate their decision. Refer to the Mental Capacity Act Code of Practice,

https://www.gov.uk/government/publications/mental-capacity-act-code-of-practice.

Speech Therapy HQ will need to involve an advocate if the person lacks capacity to

make decisions about a safeguarding concern.

Support and guidance will be sought from Adult Social Care and /or the person’s GP should

anyone have concerns regarding an adult’s capacity.

Confidentiality and Information Sharing:

Speech Therapy HQ expects all employees, volunteers and trustees to maintain

confidentiality. Information will only be shared in line with the General Data Protection

Regulations (GDPR) and Data Protection.

However, information should be shared with the Local Authority if an adult is deemed to be at

risk of harm or contact the police if they are in immediate danger, or a crime has been

committed. For further guidance on information sharing and safeguarding see Governance

Policy.

Recording and Record Keeping:

A written record must be kept about any concern regarding an adult with safeguarding

needs. This must include details of the person involved, the nature of the concern and the

actions taken, decision made and why they were made.

All records must be signed and dated. All records must be securely and confidentially stored

in line with General Data Protection Regulations (GDPR), see Privacy Policy.

Whistleblowing:

Speech Therapy HQ is committed to ensuring that employees and volunteers who in good

faith whistle-blow in the public interest, will be protected from reprisals and victimisation.

Important Contacts:

Designated Senior Lead for Safeguarding

Name: Eve Ferguson

Email address: info@speechtherapyhq.com

Police

Emergency – 999

Non-emergency – 101

Telephone: 0808 2000 247

https://www.nationaldahelpline.org.uk/

Speech Therapy HQ

EQUALITY AND DIVERSITY POLICY

SPEECH THERAPY HQ is committed to encouraging equality, diversity and

inclusion among our workforce, and eliminating unlawful discrimination.

The aim is for our workforce to be truly representative of all sections of society and

our clients, and for each employee to feel respected and able to give their best.

The organisation, in providing services, is also committed against unlawful

discrimination of customers or the public.

Our policy’s purpose

This policy’s purpose is to:

1. Provide equality, fairness and respect for all in our employment, whether

temporary, part-time or full-time

2. Not unlawfully discriminate because of the Equality Act 2010 protected

characteristics of:

 age

 disability

 gender reassignment

 marriage and civil partnership

 pregnancy and maternity

 race (including colour, nationality, and ethnic or national origin)

 religion or belief

 sex

 sexual orientation

3. Oppose and avoid all forms of unlawful discrimination. This includes in:

 pay and benefits

 terms and conditions of employment

 dealing with grievances and discipline

 dismissal

 redundancy

 leave for parents

 requests for flexible working

 selection for employment, promotion, training or other developmental

opportunities

Our commitments

SPEECH THERAPY HQ commits to:

1. Encourage equality, diversity and inclusion in the workplace as they are good

practice and make business sense,

2. Create a working environment free of bullying, harassment, victimisation and

unlawful discrimination, promoting dignity and respect for all, and where individual

differences and the contributions of all staff are recognised and valued.

This commitment includes training managers and all other employees about their

rights and responsibilities under the equality, diversity and inclusion policy.

Responsibilities include staff conducting themselves to help the organisation provide

equal opportunities in employment, and prevent bullying, harassment, victimisation

and unlawful discrimination.

All staff should understand they, as well as their employer, can be held liable for acts

of bullying, harassment, victimisation and unlawful discrimination, in the course of

their employment, against fellow employees, clients, suppliers and the public

3. Take seriously complaints of bullying, harassment, victimisation and unlawful

discrimination by fellow employees, customers, suppliers, visitors, the public and any

others in the course of the Company’s work activities.

Such acts will be dealt with as misconduct under the Company’s grievance and/or

disciplinary procedures, and appropriate action will be taken. Particularly serious

complaints could amount to gross misconduct and lead to dismissal without notice.

Further, sexual harassment may amount to both an employment rights matter and a

criminal matter, such as in sexual assault allegations. In addition, harassment under

the Protection from Harassment Act 1997 – which is not limited to circumstances

where harassment relates to a protected characteristic – is a criminal offence.

4. Make opportunities for training, development and progress available to all staff,

who will be helped and encouraged to develop their full potential, so their talents and

resources can be fully utilised to maSpeech Therapy HQimise the efficiency of the

organisation.

5. Make decisions concerning staff being based on merit (apart from in any

necessary and limited exemptions and exceptions allowed under the Equality Act).

EQUALITY AND DIVERSITY

6. Review employment practices and procedures when necessary to ensure

fairness, and also update them and the policy to take account of changes in the law.

7. Monitor the make-up of the workforce regarding information such as age,

seSpeech Therapy HQ, ethnic background, sexual orientation, religion or belief, and

disability in encouraging equality, diversity and inclusion, and in meeting the aims

and commitments set out in the equality, diversity and inclusion policy.

Monitoring will also include assessing how the equality, diversity and inclusion policy,

and any supporting action plan, are working in practice, reviewing them annually,

and considering and taking action to address any issues.

Agreement to follow this policy

The equality, diversity and inclusion policy is fully supported by senior

management/the Director.

Our disciplinary and grievance procedures

Details of the organisation’s grievance and disciplinary policies and procedures can

be found at within SPEECH THERAPY HQ’s disciplinary policy and procedure

document. This includes with whom an employee should raise a grievance, in this

case the Director of SPEECH THERAPY HQ.

Use of the organisation’s grievance or disciplinary procedures does not affect an

employee’s right to make a claim to an employment tribunal within three months of

the alleged discrimination.

This policy was last reviewed on 7.11.25.

Eve Ferguson

SPEECH THERAPY HQ Position: Director

CODE OF PROFESSIONAL CONDUCT POLICY

Speech Therapy HQ

Version 1

CODE OF PROFESSIONAL CONDUCT POLICY

Speech Therapy HQ

OVERVIEW

Our aim at Speech Therapy HQ is to provide excellent speech and language therapy

services to children and adults, either through schools, nurseries care or nursing

homes who commission our services, families who contract from us or third-party

organisations such as fostering agencies or charities. Professional conduct is of the

utmost importance for all staff at Speech Therapy HQ and is vital in our work with all

of our clients.

PURPOSE

The purpose of this policy is to set out Speech Therapy HQ’s approach to

professional conduct for staff and students on placement. This policy statement

should be read alongside our company policies, procedures, guidance and other

CODE OF PROFESSIONAL CONDUCT POLICY

Speech Therapy HQ

Version 1

CODE OF PROFESSIONAL CONDUCT POLICY

Speech Therapy HQ

OVERVIEW

Our aim at Speech Therapy HQ is to provide excellent speech and language therapy

services to children and adults, either through schools, nurseries care or nursing

homes who commission our services, families who contract from us or third-party

organisations such as fostering agencies or charities. Professional conduct is of the

utmost importance for all staff at Speech Therapy HQ and is vital in our work with all

of our clients.

PURPOSE

The purpose of this policy is to set out Speech Therapy HQ’s approach to

professional conduct for staff and students on placement. This policy statement

should be read alongside our company policies, procedures, guidance and other

Speech Therapy HQ Child Safeguarding Policy

The policy is based on national guidance and the Children Act 1989, Children Act 2004, and

“Working Together to Safeguard Children” (2023).

Introduction:

This policy ensures that Speech Therapy HQ has all the right measures in place to protect

and safeguard children and young people.

Speech Therapy HQ believes that every child and young person has the right to live in

safety, free from abuse and neglect. This policy sets out the roles and responsibilities of

Speech Therapy HQ in working together to promote children’s welfare and protect them

from harm. Employees, trustees and volunteers must be made aware of how to access this

policy.

This policy and related procedures apply to all staff, employees, volunteers, contractors and

students of Speech Therapy HQ. Failure to comply may result in disciplinary action or

exclusion from the organisation.

Definition of a Child:

Under the Children Act 1989, a child is defined as anyone who has not yet reached their

18th birthday.

Key Principles of Child Safeguarding:

 Welfare of the child is paramount

 Protection – Children must be protected from maltreatment.

 Prevention – Taking action before harm occurs.

 Partnership – Effective collaboration with parents, carers, professionals, and local

authorities.

 Proportionality – Responding appropriately to the level of risk.

 Empowerment – Respecting children’s voices and involving them in decisions where

possible.

 Accountability – Transparency in safeguarding decision-making.

Recognising the Signs of Abuse:

All Speech Therapy HQ staff, volunteers, and students are well placed to identify concerns.

Children may tell you something directly or show indicators through behaviour, play, or

communication.

All staff must know what to do and where to seek help, support and advice.

Types of Abuse:

 Physical abuse – Hitting, shaking, throwing, poisoning, burning, drowning, or otherwise

causing physical harm.

 Emotional abuse – Persistent emotional maltreatment, humiliation, bullying (including

online), or unrealistic expectations.

 Sexual abuse – Forcing or enticing a child to take part in sexual activities (including

online), whether or not the child is aware of what is happening.

 Neglect – Persistent failure to meet a child’s basic physical and/or psychological needs.

 Child Sexual Exploitation (CSE) – Exploitative situations where a child receives

something (e.g., gifts, affection, status) in exchange for sexual activity.

 Child Criminal Exploitation (CCE) – Including involvement in county lines or gang-

related activity.

 Online abuse – Any form of abuse that occurs via the internet.

 Bullying and Cyberbullying – Including prejudice-based and discriminatory bullying.

 Radicalisation and Extremism – Where children are drawn into extremist ideologies or

terrorism.

Reporting Concerns:

Any member of staff, volunteer or student who becomes aware that a child is, or may be, at

risk of abuse or neglect must raise the concern immediately with their supervisor or the

Designated Safeguarding Lead (DSL).

If a child is in immediate danger, contact the Police (999) or Children’s Social Care.

Early sharing of information is key to effective safeguarding. No one should assume that

someone else will take action.

Safe Recruitment & Selection:

Speech Therapy HQ is committed to safe recruitment practices that reduce the risk of harm

to children from unsuitable individuals.

All staff and volunteers must:

 Complete Enhanced DBS checks with children’s barred list

 Provide references

 Complete safeguarding training before starting work

Social Media and Online Conduct:

All staff and volunteers must follow the organisation’s Acceptable Use of Technology Policy

and Code of Conduct.

Staff must maintain professional boundaries with children and families at all times and

should not communicate via personal social media or messaging platforms.

Allegations Against Staff or Volunteers:

If an allegation is made against a member of staff, volunteer, or anyone in a Position of

Trust, it must be reported to the Designated Safeguarding Lead immediately.

Speech Therapy HQ will follow Local Authority Designated Officer (LADO) procedures to

ensure all concerns are managed appropriately and transparently.

Training and Awareness:

All employees, volunteers and students will receive appropriate safeguarding training to

enable them to:

• Recognise signs of abuse and neglect

• Understand their roles and responsibilities in safeguarding

• Know how to report concerns

• Maintain appropriate professional boundaries

Training must be updated at least every three years or sooner as required.

Confidentiality and Information Sharing:

Speech Therapy HQ expects all staff, volunteers and trustees to maintain confidentiality in

line with Data Protection Act 2018 and UK GDPR.

Information will be shared only when necessary to protect a child, in accordance with

government guidance “Information Sharing: Advice for Practitioners” (2018).

Recording and Record Keeping:

A written and dated record must be kept of any safeguarding concern, including:

• Details of the child

• The nature of the concern

• Who was involved

• Actions taken and rationale

Records must be securely stored and only accessible to authorised personnel.

Whistleblowing:

Speech Therapy HQ is committed to ensuring that employees and volunteers who raise

safeguarding concerns in good faith will be protected from reprisals or victimisation.

Important Contacts:

Designated Safeguarding Lead (DSL):

Name: Eve Ferguson

Email: info@speechtherapyhq.com

Deputy DSL:

Name: [Insert name]

Email: [Insert email]

Police:

Emergency – 999

Non-emergency – 101

NSPCC Helpline: 0808 800 5000

Childline: 0800 1111

ACCEPTABLE USE OF TECHNOLOGY

Version 1

ACCEPTABLE USE OF TECHNOLOGY

PURPOSE

The purpose of this policy is to set out Speech Therapy HQ’s (the “Company”)

guidance on the acceptable use of technology and to ensure the risks associated

with inappropriate or unauthorised use of computer technology are adequately

managed to support the Company’s objectives and protect clients.

For the purpose of this policy, technology includes, but is not limited to, computers,

laptops, mobile devices, internet, software, systems, email, telephones, voice mail

and related equipment (“Company Technology”). This may also include personal

computers, telephones etc being used for the purposes of the Company

Users of Company technology must respect the rights of other users, respect the

integrity of the Company technology and observe all relevant laws and regulations.

SCOPE

This Policy applies to all employees (including temporary employees, Affiliates and

Student SLTs) who use the Company technology. It should be read in conjunction

with the Company’s GDPR and Privacy Policy.

RESPONSIBILITIES

(a) Acceptable Use: If staff are using Company technology, they are expected to use

it for legitimate business purposes. Users are expected to exercise good judgment

and professionalism in the use of all Company technology. Incidental and occasional

personal use of Company technology is permissible as long as it does not interfere

with workplace productivity or the Company's systems or business operations, does

not pre-empt any business activity, does not consume more than a trivial amount of

the Company's resources and is lawful. Users should be aware that all use of

Company technology is subject to monitoring as described in this policy and as such,

users have no right to, or expectation of, privacy with respect to their use of

Company technology, subject to applicable laws.

(b) Unacceptable Use The relationship between the Company and its users is based

on trust. This trust must be maintained at all times as it is fundamental to the

employment relationship. Users must, at all times, hold themselves to the highest

standards of conduct so as to maintain the Company's reputation and the integrity of

the Company's business. Users shall not be permitted to use any of the Company

Technology to:

 solicit or recruit for any non-job-related commercial ventures, religious or

political causes, outside organizations or other non-job-related solicitations,

 store, access, transfer, download, upload, communicate or create any

fraudulent, harassing, embarrassing, sexually explicit, profane, obscene,

intimidating, libelous, slanderous, threatening, abusive, defamatory, or

otherwise unlawful or inappropriate materials,

 download entertainment software or games, or to play games over the

Internet, unless games are specifically for the purpose of providing direct

intervention with clients and clients are involved at all times,

 access Internet sites for gambling or any illegal activity,

 embarrass the Company or jeopardize the Company’s reputation,

 download, store or transmit material that infringe any copyright, trademark or

other proprietary right,

 post or transmit proprietary or confidential information related to clients,

suppliers, vendors, allied parties, or other third parties,

 post or store Company business-related information on public storage sites,

 download or distribute pirated software or data,

 deliberately propagate a virus, malware, or any other malicious program code,

 send confidential Company information without prior authorisation from the

Director. Such confidential information includes, but is not limited to, Company

copyrighted materials, log in details, trade secrets, intellectual property,

proprietary financial information, employee information, client information (with

the exception of encrypted clinical reports to parents and/or other

professionals with consent), or other similar materials that would be

considered confidential in nature,

 engage in activities for personal gain or a personal business, or for any

commercial or business purposes other than Company purposes,

 violate any applicable laws, including without limitation, those laws relating to

discrimination and harassment, privacy, financial disclosure, intellectual

property and proprietary information, defamation, and criminal laws.

 send unsolicited email,

 install or use peer-to-peer file-sharing programs or access those types of

networks,

Users should report any suspected unacceptable use of Company technology to the

Director. Any User who uses Company Technology for any of these unacceptable

uses will be subject to discipline in accordance with this policy.

MONITORING

The Company maintains ownership over all Company technology and all data

created, sent, received or stored on or using Company technology. Users should

have no expectation of privacy with respect to their use of Company technology.

Subject to compliance with applicable laws, the Company reserves the right to, and

may from time to time inspect users' use of Company technology and any

information accessed, created, modified, stored, sent, received, copied, manipulated

or otherwise handled in any way, by or through any Company technology, at any

time, in its sole discretion, without notice to any user. These actions will be

performed only as reasonably necessary to ensure compliance with this policy and

other Company policies, to detect and prevent loss or theft of confidential

information, personal information or other misconduct, or to conduct investigations

into suspected inappropriate or unlawful activity.

SECURITY AND CONFIDENTIALITY

The Company reserves the right to implement controls in respect of Company

technology at any time in its sole discretion where it is deemed necessary to protect

the security of the Company technology, confidential information, personal

information or other assets. Users may not block, uninstall or otherwise interfere with

such controls.

Users must maintain basic controls to prevent Company technology assets being

lost or stolen, potential security breaches, leaking of confidential Information or

personal information and breaches of software licensing agreements. Users must

maintain confidentiality and exclusive control of authentication credentials

(passwords) used to access the Company technology.

PASSWORD POLICY

This sub-policy specifies the rules that must be applied with regards to the use of

passwords to control access to all company-owned computers, servers, tablets and

smartphones and any equipment used to undertake work on behalf of Speech

Therapy HQ:

1. Access to all company-owned computers, servers, tablets and smartphones and

any equipment, including routers, firewalls and applications used to undertake work

on behalf of Speech Therapy HW (i.e., employee-owned equipment) must require

the submission of either a password or fingerprint ID to enable access to it.

2. All passwords must be unique to each individual user authorised to use the

equipment and they must not under any circumstances be shared or disclosed by an

employee or consultant with any other person outside of the organisation.

3. All passwords must be of a minimum strength of 8 characters (excluding mobile

phones) and contain a mixture of upper- and lower-case letters, numbers, and

characters. All passwords used for mobile phones that do not offer fingerprint ID

must be a minimum of 6 digits.

4. Passwords must be unique to each access and not used to access other systems

either work related or personal

5. Wherever possible, passwords must only be held and recorded within a password

management software application approved by the Director.

6. Passwords must not contain easily identifiable terms – including (but not limited

to) email addresses, any name (i.e., first, last, relative, colleague, etc.), home

address, birthdays.

7. The displays of all company-owned computers, servers, tablets and smartphones

and any equipment used to undertake work on behalf of company (i.e., employee-

owned equipment) must have a timeout of 5 minutes or less where the user is

prompted to enter a password to access the system.

8. Whenever an employee or user of company-owned computers, servers, tablets

and smartphones or any equipment used to undertake work on behalf of the

Company suspects that the password used to access that device is compromised, it

must be reported immediately to the Director, and the password must be changed,

Other basic controls include, but are not limited to:

 changing passwords at least every 6 months. The same password cannot be

used more than once every 24 passwords,

 keeping laptops, mobile devices and portable storage devices and media

appropriately secured (e.g. not leaving these items unattended in a vehicle or

public place),

 preventing unauthorised changes being made to the operating system

software or configuration of personal computers or mobile devices used to

access Company technology,

 not sharing mobile devices used to access Company technology, or portable

media containing confidential Information or assets, with third parties

(including family members); Users must exercise caution when opening

attachments or selecting links (these can be contained in electronic

messages, blogs or social networks) from unknown sources as these may

contain malicious software (also known as malware, examples include

viruses, worms and trojans).

The Company reserves the right to revoke access to or use of any or all Company

technology at any time at its sole discretion. Access to Company technology will be

revoked when a user leaves the Company. All Company technology resources must

be returned to the Company at the end of a user's employment, or at any time the

Company deems it necessary.

EMPLOYEE OWNED TECHNOLOGY EQUIPMENT

In addition to the password guidance, the following points apply to any equipment

used to undertake work on behalf of the Company (i.e., employee-owned

equipment):

 Any documentation including reports, treatment plans etc that contain any

confidential client data should be uploaded to the cloud-based CarePatron

system and/or shared with relevant individuals as password protected

documents. These documents should then be deleted from the

employee-owned or Company equipment, including from the deleted

items/trash folder, download folders or external hard drives. It is

preferable NOT to use external hard drives, but if these are used, they

should be password protected and stored within a locked cabinet within

the employee’s home.

 Any case histories, reports or information that has been provided by third

parties that contains ANY client information should be uploaded onto the

cloud-based CarePatron system then deleted as above.

 Any photographs of clients taken as part of the clinical assessment process

(with consent from parents/carers) or audio files should be deleted once the

clinical photographs have been uploaded onto Carepatron or the audio

transcript has been recorded in writing, if needed.

BREACHES, INVESTIGATIONS AND DISCIPLINE

All users must comply with this policy at all times and take care to ensure that their

use of Company technology does not jeopardize the interests of the Company,

breach data protection/GDPR.

Users must immediately notify the Company of any suspected breach of this policy.

The Company will investigate any reasonably suspected breach of this policy

promptly and impartially. In the course of an investigation, the Company may require

a written statement from the user involved in or with knowledge of the suspected

breach, as well as an interview of any person with knowledge of the incident and

collect any and all relevant and material documents and other evidence.

All users are expected to cooperate fully in any investigation pursuant to this policy.

If, after investigation, the Company finds that a violation of this policy has occurred,

the Company will determine what remedial action should be taken to avoid future

incidents and to ensure compliance with this policy in the future. Any such remedial

action will be undertaken in accordance with this policy. Any and all breaches of this

policy will be treated with the utmost seriousness by the Company. Any breach of this policy will result in discipline, up to and including termination of employment for

just cause.

ADMINISTRATION

This policy shall be administered in accordance with all applicable UK laws and

regulations. The Company may amend this policy from time to time, at its sole

discretion. Users are responsible for regularly reviewing this policy.

QUESTIONS

Any questions regarding this policy should be directed to the Director.

This policy was last reviewed on 07.11.25.

Name: Eve Ferguson

Position: Director

C. Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data	NO
D. Commercial information	Transaction information, purchase history, financial details, and payment information	NO
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements	NO
G. Geolocation data	Device location	NO
H. Audio, electronic, sensory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	NO
J. Education Information	Student records and directory information	NO
K. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	NO
L. Sensitive personal Information		NO

Speech Therapy HQ

Health and Safety Policy

Speech Therapy HQ

Adult Safeguarding Policy

Speech Therapy HQ

EQUALITY AND DIVERSITY POLICY

CODE OF PROFESSIONAL CONDUCT POLICY

Speech Therapy HQ

Version 1

CODE OF PROFESSIONAL CONDUCT POLICY

Speech Therapy HQ

Version 1

Speech Therapy HQ Child Safeguarding Policy

ACCEPTABLE USE OF TECHNOLOGY

PRIVACY POLICY

SUMMARY OF KEY POINTS

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

Information automatically collected

Google API

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

Google Analytics

6. HOW LONG DO WE KEEP YOUR INFORMATION?

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

8. WHAT ARE YOUR PRIVACY RIGHTS?

9. CONTROLS FOR DO-NOT-TRACK FEATURES

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Categories of Personal Information We Collect

Sources of Personal Information

How We Use and Share Personal Information

Your Rights

How to Exercise Your Rights

Request Verification

Appeals

California 'Shine The Light' Law

11. DO WE MAKE UPDATES TO THIS NOTICE?

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?