At Speros Consulting Limited, we take the privacy of the children, young people and families we work with seriously. We’re committed to protecting your privacy and handling your information in a responsible way while you use our website and our education and neurodiversity support services. We understand that the information you share with us about your child and your family is sensitive, and we operate in a highly confidential environment. This policy sets out how data is collected and processed through the use of our website and when you use our services.
We encourage you to read this policy alongside any other privacy notices we might provide, so you’re fully in the loop about how and why we use your information.
Who’s in charge of your data?
The controller of your data is Speros Consulting Limited, and Dr Susanna Pinkus is the person responsible for managing data. She can be contacted via email at pa@drsusannapinkus.com
Not happy with something?
We’re committed to treating your personal data with respect, transparency, and care. If you ever have questions or concerns about how your data is used, we want to hear from you, and we’ll do our best to resolve things quickly and fairly. Under the Data (Use and Access) Act 2025, you have the right to raise a complaint about how your personal data is handled. Here’s how:
Step 1: Email us at pa@drsusannapinkus.com with a brief description of your concern. You don’t need to use legal language – just tell us what’s worrying you.
Step 2: We’ll acknowledge your message and respond without undue delay, usually within 10 working days.
Step 3: If you’re not satisfied with our response, you can escalate your concern to the Information Commissioner’s Office (ICO) at www.ico.org.uk.
What type of data do we collect about you?
‘Personal data’ is information that identifies you. If we’ve removed your identity (by making the data anonymous), it won’t be classed as personal data. We might collect, use, store, and share various types of personal data about you as follows:
- Identity Data – such as your name, title, date of birth and, where relevant, the name and date of birth of your child.
- Contact Data – such as your postal address, email address, telephone number and your GP’s contact details.
- Health and Neurodevelopmental Data (Special Category Data) – such as information about your or your child’s physical and mental health, wellbeing and neurodevelopmental profile (for example, diagnoses such as autism, ADHD or dyslexia), relevant developmental or medical history, assessments, consultation notes and other information relevant to the education and neurodiversity support services we provide.
- Child and Family Information – where our services relate to a child or young person, this may include information about parents or carers, family circumstances, education, safeguarding concerns and relevant professionals involved in the child’s care.
- Assessment and Professional Information – such as school reports, diagnostic reports, medical letters, background information provided by parents, young people and other professionals (where appropriate permission has been obtained), together with information obtained during consultations and assessments.
- Educational Data – such as details of your child’s school or educational setting, current provision and support arrangements, EHCP or SEND documentation, academic progress, learning needs and any adjustments relevant to supporting their education.
- Financial Data – such as payment details and records of payments made for our services.
- Transaction Data – details of appointments booked, invoices, payments and services received.
- Communication Data – records of correspondence with you by email, telephone, post, online forms or during appointments.
- Technical Data – such as your IP address, browser type, operating system, device information and information about how you use our website.
Consents for Health and Neurodevelopmental Data: We require your specific consent to process Special Category Data, so when you submit your details, we will ask you to confirm your consent to this processing.
Where we provide home education services, we may collect names, contact details, signed terms and conditions, correspondence by email, telephone or WhatsApp, consultation notes and, where relevant, examples of a child’s work for the purpose of delivering those services.
We also work directly with schools and other professionals. Where we do so, we may process the contact and professional details of relevant staff, together with information they share with us about a child or young person we are supporting.
How do we collect your personal data?
We use different methods to collect data from and about you. The majority of the time, our information is collected directly when you contact us in the following ways:
- When you enquire about and/or apply for our services;
- When you fill in any new client onboarding forms;
- When you complete any forms before or during an appointment;
- Verbally during discussions, consultations and sessions;
- Correspondence with us via post, phone, WhatsApp, email or otherwise;
- When you give us feedback or contact us;
- From third parties with written consent (e.g. schools and healthcare professionals);
- During consultations and assessments; and
- Through information provided by parents, young people and other professionals (where appropriate consent has been obtained).
Another method we may use to collect data includes the use of automated technologies or interactions, like website cookies or other similar technologies. This includes information about your equipment, browsing actions and patterns. This data collection helps us to improve user experience and to gather information about how you use our website. For more information, please refer to our Cookie Policy, which can be accessed here.
What happens if you don’t provide us with the required data?
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
What are the purposes for which we use your personal data?
The purposes for which we will be using your data include:
- To register you as a new client.
- To provide our services including to manage payments, fees and charges; and to collect and recover money owed to us.
- To manage our relationship with you, e.g. to notify you about changes to our terms or this privacy policy.
- To administer and protect our practice and this website.
- To deliver relevant website content to you.
We rely on one or more of the following lawful conditions to process your data as outlined above:
- To fulfil our contract with you;
- For our legitimate interests; or
- To comply with legal obligations.
In some scenarios, we’ll ask for your consent, especially for collecting sensitive health data. We may process your personal data for more than one lawful reason at a time, depending on the specific purpose for which we are using your data. If you’d like more information on the specific legal ground we are relying on, on occasions where we rely on more than one legal ground, please feel free to contact us.
Our Lawful Basis: Recognised Legitimate Interests
We sometimes process your personal data under what’s called a “recognised legitimate interest”. This is a lawful basis introduced by the Data (Use and Access) Act 2025. This means we use your data in ways that support important public or organisational aims, while respecting your rights and freedoms.
Examples include:
- Helping prevent fraud or misuse of our services
- Supporting safeguarding and professional standards
- Responding to emergencies or protecting wellbeing
- Improving accessibility and inclusion in our resources
We always carry out a balancing test to make sure our interests don’t override yours. You have the right to object to this type of processing at any time, and we’ll explain your options clearly.
If you’d like to know more or raise a concern, just email us at pa@drsusannapinkus.com . We’re committed to transparency and respectful data use.
Do we use Cookies?
Cookies help make our website work better for you, remembering your preferences and improving your experience. You can control cookie settings in your browser. Cookies make your browsing experience on our site as smooth as possible, because they remember your preferences.
Our website uses cookies to distinguish you from other users of our website. Please refer to our Cookie Policy here to learn more: https://drsusannapinkus.com/cookie-policy
Do we use third-party links?
Our website might link to third-party websites, tools, and apps (for example LinkedIn and Instagram). Clicking on these links may allow third parties to collect or share your data. We do not control said apps and websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy policy of every website or app you visit.
Do we ever share your personal data?
We take your data’s security seriously and only allow certain people to access it. We may share your personal data with the parties set out below for the purposes as stated further above.
- Service providers, acting as processors, who provide IT, website hosting, website design, system administration, personal assistant and IT security services.
- Professional advisers including healthcare professionals, lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Our accountants, who have access to our accounting system (Xero) and may process your personal information (including your name, contact details, appointment dates and financial and transaction data such as invoices, fees and payments) solely for the purpose of preparing invoices, bookkeeping and managing our accounts.
- If you are referred by, or your services are funded by, a third party we may need to share details such as your appointment schedule with them for the purposes of billing and to provide updates on the support provided.
- As part of maintaining our professional standards, we may discuss cases with the rest of the professional team, but only once we have written permission to do so. Where the client is a child or young person, we obtain written permission from the family. Where the young person is 18 or over, we ask them directly for written permission to share information and to liaise with their parents as appropriate.
- Where appropriate, and with your written consent, we may share information with schools, GPs and healthcare or education professionals involved in your care in order to support joined-up working and ensure the best possible outcomes. We will always get your consent prior to doing this. When the information concerns risk of harm to the client or another person, then we may need to disclose information about you without your consent for your own safety or for the safety of someone else.
- If you are referred to another professional for specialist support or assessment, your relevant information may be shared with them to ensure continuity of support and appropriate provision.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- Debt collection agencies in the event that payment is not received for services rendered. This will be done to recover any outstanding debts, and the debt collectors will process your data solely for this purpose.
- We may need to share your personal data with courts, legal representatives, or other relevant authorities for legal purposes. This includes situations where we are required to do so by law, or where it is necessary to protect your vital interests or the interests of another person. We ensure that this data sharing is conducted lawfully and with due regard for your privacy rights.
All of the above third parties have a requirement to respect the security of your personal data. We do not permit them to use your personal data for their own purposes – they are only permitted to process your data for specified purposes in line with our instructions.
Do we ever transfer your data internationally?
We may transfer your data outside of the United Kingdom, but only when we can be sure it is protected.
Many of our external third parties are based outside the United Kingdom, and so their processing of your personal data will involve a transfer of data outside the United Kingdom. For example, some of our third-party service providers (such as Google Workspace, Xero and Dext) may store data on servers in other jurisdictions
Whenever we transfer your personal data out of the United Kingdom, we make sure it is protected by at least implementing one of the following safeguards:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the United Kingdom
- Where we use certain service providers, we may use specific contracts approved by the UK Information Commissioner’s Office and the European Commission which give personal data the same protection it has in Europe.
Please contact us if you want further information on the specific process used by us when transferring your personal data out of the United Kingdom.
How secure is your data with us?
We have strong security measures in place to keep your personal information safe. Only authorised individuals who need to know are granted access to your data, such as our employees or trusted partners. They will process your data in accordance with our confidentiality terms.
Client information is stored electronically using secure cloud storage and password-protected devices, which may include contact details such as telephone numbers saved on a password-protected mobile phone. Temporary handwritten notes may be created whilst working with clients; these are securely shredded once the work has been completed.
In the rare circumstances that there is a personal data breach, we have procedures in place and will notify you, along with any applicable regulator, when we’re legally required to.
Children’s Data & Age-Appropriate Design
We’re committed to protecting the privacy of children and young people who use our services or access our resources. If our website, services or content are likely to be used by children under 18, we follow the Age-Appropriate Design Code and the updated rules under the Data (Use and Access) Act 2025.
Here’s what that means in practice:
- We design our services with children’s safety and understanding in mind.
- We avoid using unnecessary tracking or profiling tools.
- We explain things clearly, using child-friendly language wherever possible.
- We ask for parental or guardian consent when needed.
- We give children meaningful choices about their data.
If you’re a parent, guardian, or educator and have questions about how we handle children’s data, just email us at pa@drsusannapinkus.com.
Children’s Information and Consent
We work with children and young people of different ages, and the rules about consent vary depending on age and circumstances.
Age and Consent
- Under 13: We always require consent from a parent or person with parental responsibility.
- Ages 13-15: We usually require parental consent, though young people may be able to consent themselves if they fully understand the implications (assessed case-by-case).
- Ages 16-17: Young people can generally consent to processing of their health data themselves, though we may involve parents/carers with the young person’s agreement.
- Age 18+: Adults provide consent themselves. We will not share information with parents without explicit consent (except in safeguarding situations).
Verifying Parental Authority
We verify parental authority by:
- Requesting confirmation of relationship to the child.
- Checking parental responsibility (we may request documentation such as court orders if parents are separated).
- Confirming with schools or referring professionals where appropriate.
When Young People Turn 16 or 18
When a young person turns 16, they gain the right to consent to health data processing. When they turn 18, they have full control over their information. For ongoing cases, we will discuss how to manage consent and communication going forward.
Separated Parents
If parents are separated, both parents with parental responsibility generally have equal rights to information about their child, unless court orders specify otherwise. Please inform us of any relevant arrangements or restrictions.
What is our process for retaining your data?
We only keep your data as long as necessary for the reasons we collected it.
We retain emails, consultation notes, formal reports and invoices for seven years following the conclusion of our work together. Reports provided by schools, healthcare professionals or other third parties are retained only for as long as they remain necessary for us to provide our services or support our professional advice, after which they are securely deleted.
Working notes that do not include health and neurodevelopmental information, created during the course of providing our services, are temporary and are securely shredded once our work has been completed.
By law, we have to keep health and neurodevelopmental information about clients for 7 years after our work has concluded. For any children we work with, we are obliged to retain this information until the child’s 25th birthday, or their 26th birthday if they were 17 when they received our services. By law, we have to keep basic information about our clients (including contact, identity, financial and transaction data) for six years after they cease being clients for tax purposes.
Discovery Calls
Where we conduct a discovery call or initial consultation with a prospective client, the following retention periods apply:
- Where no professional judgement was formed: If the call was exploratory in nature and we collected only basic contact details (such as your name, email address and telephone number), and you do not proceed as a client, we will securely delete that information within one month of the call. This aligns with the storage limitation principle under UK GDPR.
- Where a professional judgement or risk-related decision was made: If, during the discovery call, we formed any professional assessment of suitability, noted a safeguarding concern, or made any risk-related decision, we will retain a brief record of that call even if you do not proceed as a client. This is consistent with good professional governance and is supported by UK GDPR’s provisions for processing in the context of health-related data and legal claims. In such cases, retention periods will follow applicable professional body guidance – 7 years for adults from the date of the call, and until the individual’s 25th birthday where the prospective client was a child at the time of the call.
For information that does not fall under the definition of basic, to determine the appropriate retention time, we look at what kind of data it is, how sensitive it is, the risks if it’s misused, why we need it, and if there are other ways to achieve the same goals. We also consider applicable legal, regulatory, tax, accounting and other requirements.
What are your legal rights in relation to your data?
You have the following rights regarding your personal data:
Access: You have the right to ask us what personal data we hold about you and to receive a copy of that data. This is called a Subject Access Request (SAR).
We’ll respond within one calendar month, but if we need to verify your identity first, we may pause the clock while we do so. This helps protect your data and ensures we’re sharing it with the right person. If your request is complex or repetitive, we may apply proportionality rules under the Data (Use and Access) Act 2025, which allow us to limit the scope or extend the response time. We’ll always explain why and keep you informed. To make a request, just email us at pa@drsusannapinkus.com with the subject line “DSAR Request”. You don’t need to use legal language – just let us know what you’d like to see or understand. If you’re unhappy with how we handle your request, you can raise a concern with the Information Commissioner’s Office (ICO) at www.ico.org.uk
Correction: If the personal data we have about you is incomplete or incorrect, you can ask us to correct it.
Erasure: You can ask us to delete your personal data. It’s important to note, however, that there might be legal reasons that prevent us from fulfilling this request. If such reasons exist, we will inform you when you make your request.
Objection: In certain situations, you have the right to object to the processing of your personal data.
Restriction of Processing: You can request that we restrict the processing of your personal data under specific circumstances.
Data Portability: You have the right to request the transfer of your personal data directly to you or to a third party of your choice.
Withdrawal of Consent: At any point where we rely on your consent to process your personal data, you have the right to withdraw this consent. Withdrawal of consent will not affect the legality of the processing done before the consent was withdrawn. Should you withdraw your consent, we might be unable to provide you with certain products or services. We will inform you if that is the case when you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
We won’t charge any fees for you to request access to your personal data. However, a reasonable fee may be charged if your request is clearly unjustified, repetitive or excessive. We also reserve the right not to comply in this scenario. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
Changes and Contact
We regularly review our privacy policy. Please keep us updated if your personal data changes. If you have any questions or need to exercise your rights, please be in touch.
