Policies


Policies

COMMENTS AND COMPLAINTS

I always strive and aim to provide good quality services for all.

Please do see and read my Consultancy Terms and Conditions document

Any comments, compliments and complaints will help myself to improve the services I supply, please do feel free to get in touch, via any format you prefer.

If you have been satisfied with the service I’ve provided, please do provide your feedback. I  will use this information to improve my services, for the benefit of future customers.

I continually review and update the sessions I deliver, please do feel free to contact me with ideas and thoughts, especially in the area of resources that are useful. Any suggestions or ideas about how my services could be improved, would be most welcome, to evaluate my performance and to add to my own continual personal development.

Should you have any reason to complain, please contact myself as soon as possible. It would be beneficial to myself if you could be as focused and direct as possible . The following would be useful:

The date the incident(s) occurred
The names of any people involved
The nature of the complaint as specifically as you can
The aspect of the incident/situation that you are unhappy about

I will acknowledge receipt of your complaint as soon as possible and then investigate the incident fully within 10 working days.

If there is any reason to delay the investigation I will inform you as soon as possible as to the reasons for this delay.

You will receive a formal reply to the outcome of the complaint within 20 working days.

If you are not satisfied with this response, where possible I will arrange to meet you personally, or virtually in order to reach a satisfactory conclusion for all concerned, respecting that these next steps have to be safe and accessible for all.

If you have concerns regarding any organisation that I have worked for, (it is to do with a specific presentation for example) or am affiliated to, please feel free to contact them direct also.

Covid-19 Guidance and Support

I regularly check and review Government and NHS advice in this area. Though the pandemic is now considered a much less threat to our society as a whole, I am conscious that my work will bring me into contact with vulnerable individuals  and those that will work with said individuals in a variety of settings. The awareness of current good practises, linked to an overall safe and respectful approach is paramount to my professional work.

I will adapt to the latest Government advice as it changes. In addition to the present guidelines I personally I have put in place the following measures to keep myself safe and allowing myself to continue with face to face work:
I am fully vaccinated and have relevant boosters and will provide evidence if required.
I test using the Covid-19 Rapid Lateral Flow Test and take my temperature especially when presenting and visiting sensitive areas.
I continue to take person measures to wear a face covering in crowded/enclosed spaces, to socially distance to use an approved hand wash.
When working face to face, I ensure that there is suitable ventilation and social distancing.
If I am experiencing coronavirus symptoms, been in close contact with an individual who has tested positive and required to isolate under Government guidelines for any other reason, I will contact you as soon as possible.
If I test positive close to our session I will inform you immediately. 
If you may require additional and/or altered support and I will fully adhere to any guidelines you may have in place.  Please let me know in advance with your requirements.
I would appreciate it if you could make me aware of any confirmed or potential Covid-19 cases before I arrive at your establishment. Thank you.


Privacy Policy/GDPR


David Gray-Hammond (“I”) is committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data that I collect from you, or that you provide to myself, will be processed by me.  Please read the following carefully to understand my views and practices regarding your personal data and how we will treat it. By visiting my website and by providing personal data to myself, you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is David Gray-Hammond.
I may collect and process the following data about you:
Information you give to me
This may arise from you filling in forms, by corresponding with myself, by phone, e-mail or otherwise. This includes information you provide when you complete the course membership form, course request forms and evaluation forms.
It may also arise from when you change/update your personal details, contact preferences etc. and when you report a problem with my various media sites. The information you give me may include your name, address, e-mail address and phone number.
Information I collect about you.
About each of your visits to my media sites, I may automatically collect the following information:
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet.
Your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time)
Products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call myself.
Regarding consultancy and professional services I may collect:
Location and other personal data, including but not limited to name, address, date of birth, and other information relevant to identifying you as in receipt of my services.
I am required by the terms of my insurance to keep recordings and transcripts of all video calls for a period of five years.


Cookies


All visitors to my website are notified that I collect Cookies. I will use this information:
To administer my site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
To improve our site to ensure that content is presented in the most effective manner for you and for your computer.
To allow you to participate in interactive features of my service when you choose to do so.
As part of my efforts to keep my site safe and secure.
To measure or understand the effectiveness of advertising I serve to you and others, and to deliver relevant advertising to you.
To make suggestions and recommendations to you and other users of my site about goods or services that may interest you or them.
Information I receive from other sources. I may combine this information with information you give to myself and information I collect about you. I may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
Provided always that you have provided the necessary consent(s),
If I am under a duty to disclose or share your personal data in order to comply with any legal obligation, my customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where I will store your personal data
The data that we collect from you will be stored at a within the European Economic Area (“EEA”) and will not be transferred outside the EEA unless I have your explicit consent to such transfer and storage. In any event, your data will only ever be transferred to organisations where an approved code of practice in relation to data protection is adopted. I will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
Although I will do my best to protect your personal data, I cannot guarantee the security of your data transmitted to my site; any transmission is at your own risk. Once I have received your information, I will use strict procedures and security features to try to prevent unauthorised access.
Retention Policy
I know what personal data I hold and why I need it.
I carefully consider and can justify how long I keep personal data.
All data is reviewed every twelve months. Any unnecessary date is then reviewed and deleted
I regularly review information and erase or anonymise personal data when I no longer need it.
I have appropriate processes in place to comply with individuals’ requests for erasure under ‘the right to be forgotten’.
Your rights
You have the right to ask me not to process your personal data for marketing purposes. I will always inform you (before collecting your data) if I intend to use your data for such purposes or if I intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by not checking the necessary boxes to give such consent on the forms I use to collect your data.  You can also exercise the right at any time by contacting me at david@dghneurodivergentconsultancy.co.uk
My site may, from time to time, contain links to and from the websites of any partner networks and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.
If, at any time, you want to verify, update or amend your personal data or preferences please write to myself, at david@dghneurodivergentconsultancy.co.uk
Verification, updating or amendment of personal data will take place within 28 days of your request.
Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet my costs in providing you with details of the information we hold about you.


Changes to our Privacy Policy


Any changes I may make to our privacy policy in the future will be posted on the website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to David Gray-Hammond (DGH Neurodivergent Consultancy), david@dghneurodivergentconsultancy.co.uk




CONFIDENTIALITY POLICY


David Gray-Hammond (hereby referred to as Myself, me or I) is committed to providing a confidential service to my clients.
No information given to the me will be shared with any other organisation or individual without the user’s expressed permission unless there are safeguarding implications. (See Policy) 
For the purpose of this policy, confidentiality relates to the transmission of personal, sensitive or identifiable information about individuals or organisations (confidential information), which comes into the possession of myself through my work.
I may at times hold personal data about individuals, clients and other organisation that I work with which will only be used for the purposes for which it was gathered and will not be disclosed to anyone outside of my business without prior permission.
All personal data will be dealt with sensitively and in the strictest confidence internally and externally.
Purpose
The purpose of the Confidentiality Policy is to ensure that all individuals understand my requirements in relation to the disclosure of personal data and confidential information.
Principles
All paper-based and electronic data must be stored in accordance with the Data Protection Act 1998 and must be secured against unauthorised access, accidental disclosure, loss or destruction.
All personal paper-based and electronic data must only be accessible to those individuals authorised to have access.
Statistical Recording
I am committed to effective statistical recording of the use of its services, through completed evaluation forms, in order to monitor usage and my performance.
Any statistical records given to third parties, such as to support funding applications or monitoring reports for organisations that we provide my services to, or the local authority, shall be produced in anonymous form, so individuals or organisations cannot be recognised.
Records
I predominantly keep digital records upon my main computer and are also backed up on an external hard drive and a secure google drive. All are password protected.
These digital records are kept upon a password protected computer and hard drive using windows 11 and a password protected google drive.
Individual folders are then further encrypted via separate encryption software, with a double keycode access. 
This hard drive is kept in a locked cabinet.
Breaches of Confidentiality
I recognise that occasions may arise where I may feel I need to breach confidentiality.
This could do with a safeguarding concern.
Confidential or sensitive information relating to an individual may be divulged where there is risk of danger to the individual, a volunteer or employee, or the public at large, or where it is against the law to withhold it.
In these circumstances, information may be divulged to external agencies e.g. police or social services on a need to know basis.


Legislative Framework


David Gray-Hammond will monitor this policy to ensure it meets statutory and legal requirements including the Data Protection Act, Children’s Act, Rehabilitation of Offenders Act and Prevention of Terrorism Act.
Confidential Paperwork
In accordance with my privacy and confidential policies, any documents, paper based or digital, relating to my employment, will be stored in a locked filing cabinet, and/or digitally in password protected folders upon my computer only.
As mentioned, any information sent to me, will be sent at your own risk.
I will do my utmost to ensure it is stored in a safe and secure way, and shredded/securely deleted upon competition of my employment.
If training, within 24 hours of competition. If consulting, this will be discussed with my “point of contact” and all documents will be shredded/deleted within 24 hours.
If there is any information of cyber breach, I will inform the Data Protection Officer and my point of contact for the relevant employment(s) at relevant organisations/individuals.
I confirm I registered with the Information Commissioners Office. I also hold a current Enhanced DBS check.


EQUALITY AND DIVERSITY POLICY


David Gray-Hammond is dedicated to encouraging a supportive and inclusive culture amongst all who we interact with. It is within my best interest to promote diversity and eliminate discrimination in the workplace and to act in accordance with the Equality Act 2010.
My aim is to ensure that all individuals are given equal opportunity and that my work is representative of all sections of society. Each individual I interact with will be respected and valued and able to give their best as a result.
This policy reinforces my commitment to providing equality and fairness to all in my interactions and not provide less favourable facilities or treatment on the grounds of Neurotype, age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, ethnic origin, colour, nationality, national origin, religion or belief, or sex and sexual orientation. I am opposed to all forms of unlawful and unfair discrimination.
As a consultant, advocate, and trainer, every individual will be treated fairly and with respect.
All individuals will be given help and encouragement to develop their full potential and utilise their unique talents. Therefore, the skills and resources of my organisation will be fully utilised, and we will maximise the efficiency of myself.

David Gray-Hammond’s commitments:
To create an environment in which individual differences and the contributions of all individuals are recognised and valued.
To create a working environment that promotes dignity and respect for every Individual.
To not tolerate any form of intimidation, bullying, or harassment, and to inform relevant individuals of any issues in this area.
To promote equality in all our interactions, which David believes is good management practice and makes sound business sense.
To encourage anyone who feels they have been subject to discrimination to raise their concerns so I can apply corrective measures.
To encourage all to treat everyone with dignity and respect.
To regularly review all these practices and procedures so that fairness is maintained at all times.
To adhere all policies and procedures related to this area for each employer that I provide a service for.
David will inform all that an equality and diversity policy is in operation and that they are obligated to comply with its requirements and promote fairness during all our interactions. The policy will also be drawn to the attention of funding agencies, stakeholders, customers, learners, and job applicants.
This equality and diversity policy is fully supported by myself (David).
This policy will be monitored and reviewed annually to ensure that equality and diversity is continually promoted in the workplace and all my interactions.


SAFEGUARDING POLICY


Services
Please read my Terms and Conditions
I am not a professional therapist or counsellor. I use my professional experience and personal insight when consulting with individuals or families.
I will require emergency contact details, both phone and address, (from where the consult is taking place), upon the initial consult form. This will not be shared unless I have major concerns about the welfare of the individual I am consulting with or another relevant individual per the nature of any disclosure (adult or minor).
All sessions are recorded and transcribed, and by engaging my services you consent to this.
Nothing we discuss will be shared with a third party, unless I have concerns about a relevant individuals safety and wellbeing as noted above.
Individuals under 18 years of age.
For individuals under 18 years old, I will require confirmation of permission from a parent/guardian/responsible adult before we begin. I prefer this via email, in writing.
A parent or guardian will be present at all interactions

Use of Zoom/Google Meets, etc


When in contact via a digital device, I will discuss our safety before we begin the session.
When using Zoom/Google Meets, etc, be aware that everything we say can be heard, and that the image behind you will show your present environment, which may be your home.
I use the “Admit” feature on Zoom and Google Meets to ensure that the contact is only you and I.
I use Zoom or Google Meets when consulting, ( I can use other formats). All my electronic devices require several levels of security, Biometric, to pin/swipe pattern to then access folders etc.
I also hold a Professional Indemnity Policy, have an enhanced DBS and am a member of the ICO.
I am a Practitioner Member of Addiction Professionals (Membership No. 7155) and a Professional Member of International Society of Substance Use Professionals and therefore subject to their ethics and practice guidelines.