Data Controller:
Erinn Winter (Registered Midwife and Lactation Consultant IBCLC)
15 Evans Grove
Biggleswade
Bedfordshire
SG18 8JG

07811 817906
01767 310048
erinnwinter@protonmail.com

Infant Feeding Specialist Services Ltd is registered with the Information Commissioner’s Office
www.ico.org.uk
ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
0303 123 1113

Complaints can be made to the ICO if you are unhappy with how I have handled your personal data. You can also complain to me at the address and contact details above.


1. Relevant personal data obtained during a consultation and by phone, text, messenger, WhatsApp and email will be recorded in the client record that I keep. Information within each client record is obtained from the baby’s parent or carer with parental responsibility. I use your contact details for purposes of follow up, obtaining payment and for anything else relevant to our contract. Please be aware that communications by text, email, messenger and WhatsApp may not be secure due to the technology being used. Client records from March 2019 are electronic; prior to that they are handwritten and stored securely. Clients sometimes send me photos- I reply to these messages and delete the photo when I reply. This is via my phone or laptop, both of which are password protected devices.

2. A copy of your encrypted notes is emailed to you after the consultation. This is from a secure encrypted provider (Protonmail). The email is password protected, as are the attached notes. The passwords to open these will be texted to you after the consultation. This email, with the attached notes, is accessible for 28 days. After this time, it self-destructs and is no longer stored in my account or accessible. Please contact me if you need your notes resending after this expiration period.

3. Handwritten notes and paper consent forms are locked in a fireproof metal filing box with the keys stored in a fireproof safe. Electronic notes (Word documents) are encrypted and stored on a password-protected device, with security software installed. They are backed up on two rotating memory cards, stored in a fireproof safe when not being used. Notes are taken in accordance with the Nursing and Midwifery Council’s (NMC) Code, being clear, accurate and relevant to my practice. Storing all of the information recorded during the consultation and afterwards, helps me to plan care appropriately and to demonstrate that care provided has been necessary, justified and safe.

4. I may use anonymous information from your notes (e.g. to consider whether treatment provided had a beneficial outcome) in my own supervision and with discussion with other tongue tie practitioners- no identifying data will be shared. Regular audits will monitor that care is safe, effective, caring, responsive and well-led in accordance with the Care Quality Commissions’ standards (www.cqc.org.uk). Results of audit will be anonymous and may be compiled into a report or shared amongst a wider audience, for example amongst other tongue tie practitioners. Peer review audits can be used for revalidation purposes (a three-yearly process for midwives to maintain professional registration with the NMC). Audit reports will be maintained for CQC inspection. Audits may be conducted with other practitioners so we can draw on findings at both a local and national level. The wider the clinical audit the more accurate the results.

5. I will use your personal data when forming and enforcing the contract between us. Before our first appointment, I email you a copy of my terms and conditions and information related to the appointment. You can read in advance about the service I offer, what to expect, and associated charges. An updated copy of my privacy notice is on my website, and this can be accessed from my ATP (Association of Tongue-tie Practitioners) listing (www.tongue-tie.org.uk).

6. Medical records will be kept for 25 years from the infant’s date of birth. This is a legal requirement. At this time they will be securely destroyed.

7. Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to request access, correction, objection or restriction to processing, and withdrawing consent (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual....

8. With your consent, data may be shared with other health care professionals (GP, Health Visitor, Midwife) to enable you to gain extra care and support. In cases of suspected potential harm to you or others, I may contact other professionals without your consent (GP, Health Visitor, Midwife, child and adult safeguarding services, emergency services or non-emergency police). The need to report safeguarding concerns will override client confidentiality, but my aim is to include you wherever possible in any decision-making and involvement of other health care professionals or agencies. This may be by phone call or posted letter (via Royal Mail). I will inform your GP and Health Visitor if I have released your baby’s lingual frenulum, but only with your consent (posted letter via Royal Mail).

9. Your notes may be viewed by a Care Quality Commission inspector when I am inspected.

10. I am insured with Hiscox (Professional Indemnity) and Aviva (Public Liability). Relevant information would be shared with them, and my legal support, in the event of a complaint or claim being made against me. I have access to a mediation service and your consent would be sought if I suggest we use this. As an independent practitioner, I am a member of the ATP. On occasion I may seek support from colleagues, whilst maintaining client confidentiality.

11. In cases of payment by bank transfer, your data related to payment will be stored via the transfer made, along with my chosen online accountancy software which my accountant will have access to. Involvement of a third party in pursuing non-payment of fees owed may result in your details being shared with those involved in obtaining payment (e.g. court action). If an alternative electronic payment method is made, you will be accepting the storage of your details by any third party involvement, available on the company website (e.g. card reader company or other online platform).

12. Access to your data is free, please contact me at the above address, on my website, and linked via my ATP listing, (www.tongue-tie.org.uk).

13. In the event of expected serious decline in my health, or sudden death, Adam Winter will become the Data Controller. He is registered at the same address (15 Evans Grove) and landline number (01767 310048). Please contact me (or Adam) for a copy of my ‘Illness or Death of Provider Policy’.

Updated 9/2/24