Information handling and privacy

a. BABCP is committed to keeping any records relevant to complaints made under this Procedure, including those containing personal information, safe and meeting its responsibilities under law.

b. Records will be processed, maintained, and stored for the purposes of this Procedure in accordance with UK data protection legislation, BABCP’s Privacy Policy, any applicable BABCP information governance policies and procedures, and any other relevant legislation or standards.

c. Records under this Procedure may include:

i. details about complaints made under this Procedure;

ii. information relating to the Member who is the subject of a complaint under this Procedure;

iii. therapeutic records under section 8(d)(viii);

iv. evidence, including transcripts and excerpts of transcripts, provided by the Member, the Complainant or witnesses;

v. audio and/or video recordings of Panels and meetings held under this Procedure. These will usually be deleted once the minutes of the proceedings have been finalised and approved;

vi. minutes or excerpts of minutes created for the purposes of this Procedure;

vii. any other information or documents considered relevant by BBCP to the investigation of a complaint under this Procedure.

d. BABCP will only collect, create, process and retain records that BABCP considers are relevant and proportionate to the matters under consideration in connection with this Procedure.

e. Such records may be disclosed or made accessible:

i. to persons who require access for the purposes of this Procedure;

ii. to the individuals involved in a complaint under this Procedure, including the Member, the Complainant, any witnesses who have given evidence to the Panel and other relevant third parties, subject to any necessary edits, redactions or restrictions for confidentiality, safeguarding, privacy or public protection reasons;

iii. to the Professional Standards Authority (PSA) or other appropriate bodies where BABCP considers it lawful, necessary and proportionate to do so, including where there is an applicable information sharing agreement or memorandum of understanding;

iv. in accordance with section 40 below;

v. to contractors and suppliers supplying services on behalf of BABCP (such as for the purposes of preparing transcripts) and who will be subject to confidentiality and data protection agreements;

vi. to BABCP’s professional advisers, including legal advisers;

vii. to regulatory bodies such as the Charity Commission;

viii. where required by law, court order, safeguarding obligations or other overriding public protection considerations;

ix. to any other person or organisation that BABCP considers appropriate.