High Tech photo use

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aaccampuk

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Jan 25, 2021, 7:42:47 AMJan 25
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Hi All-Can anyone point me to a document that give guidance around the issue of photograph consent, using photos of people in high tech AAC devices? We've never had issues with using photographs in books but using them in high tech, as always, makes things a little more complicated. Any answers?

TIA
Dan

Wendy Day - southview - Communication

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Jan 25, 2021, 7:55:34 AMJan 25
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Hi Dan

AT school where I work we have added a separate column specifically for the use of photographs in communication books as well as devices that go home and out in the community, this is part of the pemissions form/document, we only add the photographs if we have a yes response if there is no response it is a no. I hope that makes sense not sure if it helps but as far as I now it meets data protection issues.

Kind regards
Wendy
From: cm-aac...@googlegroups.com <cm-aac...@googlegroups.com> on behalf of aaccampuk <aacc...@gmail.com>
Sent: 25 January 2021 12:09
To: CM AAC Forum <cm-aac...@googlegroups.com>
Subject: [AAC Forum] High Tech photo use
 
Hi All-Can anyone point me to a document that give guidance around the issue of photograph consent, using photos of people in high tech AAC devices? We've never had issues with using photographs in books but using them in high tech, as always, makes things a little more complicated. Any answers?

TIA
Dan

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Caroline Fitzgibbon

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Jan 25, 2021, 8:24:56 AMJan 25
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HI Dan

I put together a easy read consent form for service users to consent to pics, video and audio recordings of themselves.

Happy to send it to you so you can tweek

Thanks

Caroline

 

From: cm-aac...@googlegroups.com [mailto:cm-aac...@googlegroups.com] On Behalf Of aaccampuk
Sent: 25 January 2021 12:10
To: CM AAC Forum <cm-aac...@googlegroups.com>
Subject: [AAC Forum] High Tech photo use

 

Hi All-Can anyone point me to a document that give guidance around the issue of photograph consent, using photos of people in high tech AAC devices? We've never had issues with using photographs in books but using them in high tech, as always, makes things a little more complicated. Any answers?


TIA

Dan

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Tess Reddington

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Jan 25, 2021, 10:26:04 AMJan 25
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following with interest - I'd be interested to see some tried and tested guidelines.  We follow general data protection rules where necessary and have a standard consent form which we have used when we are taking images to use as icons, in a group setting such as on a college course etc, and where the people whose image we are storing may not have the cognitive ability to consent verbally at the time, but other than in those settings,  because Richard is an individual and the images stored on his device are personal (in the same way any individual's electronically stored photos of friends are) I think we are outside the scope of ICO.   There are some important questions about who owns the content, but for me, Richard's electronic voice is as important to him as my natural voice is to me and what is most important is that he can search his "memory" and retrieve the right name for whoever, whenever he pleases. 
I do hope any guidelines are not restrictive. 

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Fil McIntyre

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Jan 26, 2021, 4:50:37 AMJan 26
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Hello,

I sought guidance on this from the ICO as I was concerned that GDPR could override good practice around communication and safeguarding.

Organisations would not automatically be in breach of GDPR if they use devices with photos of relevant people on
BUT
1. It must be in the *legitimate interests* of the organisation and they need a *lawful basis* to collect the information.  (* are legal terms - links to what they mean in the PP)
2. Organisations would still need to comply with GDPR in the usual ways - such as: Retention policy, minimum data possible is collected, limiting data to photo and first name where possible and ensure that the data is only used for the stated purposes.
3. Procedures should be put in place to avoid a device being lost where possible. Signing them out and having remote wipe options if a device is reported lost.
4. If the device belongs to the individual it is not covered by GDPR but to me this is a grey area of the organisation is taking responsibility for putting data onto the device and probably backing it up too.

My overall impression is that if best practice is followed and procedures are in place - minimum data, remote wipe capability, reporting etc. then the ICO would not take action. 
There is an image of the flowchart we use at Beaumont to ensure best practice is followed.

Fil

Fil McIntyre

Lead Assistive Technologist

Beaumont College

Slyne Road

Lancaster

LA2 6AP

01524 541400

mobile: 07436810634

twitter: @filmcintyre

Fil McIntyre

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Jan 26, 2021, 5:05:44 AMJan 26
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Sorry just to add to this.
The vast majority of general data breaches happen with paper documents.  
The same rules apply to photos/names in books and these are probably at a greater risk of loss than digital.  
Once a book is lost there is no way to remotely wipe, there is no encryption...

Top tip I got from a Group Data Protection Officer was to never use the word "data", always use "information" when writing guidance.  People think "data" means digital.

Fil

jayne....@jfspeechandlanguagetherapy.co.uk

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Jan 26, 2021, 5:09:07 AMJan 26
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Really useful – thanks for the information and the powerpoint Fil.

 

Jayne Foxley 

Independent Speech and Language Therapist

07929231595

image002.png

Sarah Keddy

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Jan 26, 2021, 5:34:01 AMJan 26
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Hi Fil

 

Thanks for this.  What is the name of your MDM at Beaumont? I know you have told me once before but it was a long time ago that I have forgotten it!

 

Hope all is well!

 

Cheers,

 

Sarah

 

From: cm-aac...@googlegroups.com <cm-aac...@googlegroups.com> On Behalf Of Fil McIntyre


Sent: 26 January 2021 09:47



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Tess Reddington

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Jan 26, 2021, 5:43:34 AMJan 26
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Thanks Fil McIntire,
thats excellent and reassuring.  Best Wishes

To view this discussion on the web visit https://groups.google.com/d/msgid/cm-aac-forum/aa63256b-5318-4bb3-8d76-f87d0c9ff9ebn%40googlegroups.com.

Judith James

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Jan 26, 2021, 5:58:23 AMJan 26
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This is great advice and much appreciated.

Some very clear guidance to share with colleagues,

Judith

 

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Subject: Re: [AAC Forum] High Tech photo use

 

Thanks Fil McIntire, thats excellent and reassuring.  Best Wishes On Tue, 26 Jan 2021 at 09:50, Fil McIntyre wrote: Hello, I sought guidance on this from the ICO as I was concerned that GDPR cou

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Daniel Cooper

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Jan 26, 2021, 8:11:26 AMJan 26
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Thanks for all of your replies - lots to feedback to our team. The GDPR aspect is an interesting one as well when you consider 'About Me' messages. 
Dan

To view this discussion on the web visit https://groups.google.com/d/msgid/cm-aac-forum/8E35FF2B-8350-4E55-AACD-03C05BCCBCBC%40ecmslimited.co.uk.

Sherlock Chris

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Jan 26, 2021, 8:22:28 AMJan 26
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Here in ACT in our loan documentation for a Voice Output Communication aid we say

 

  • The equipment does not have any data security systems incorporated within. Personal information (such as names, addresses, telephone numbers, emails) stored in the equipment would be accessible to anyone who used, borrowed or stole the equipment.
  • Allowing access via TeamViewer or similar, allows the viewer to see the content of your device – please consider this before giving permission.
  • Equipment permanently returned to ACT will have any personal data/photographs/voice banking etc removed. A back up copy of the device will be securely stored in the client’s electronic file. 

 And on the about me we don’t put everything particularly for a child

Just enough for them to introduce themselves, and perhaps get themselves out of a tight spot without it being obvious all their identifying information eg full Date of Birth

 

Best Wishes

Chris Sherlock

Highly Specialised Speech and Language Therapist

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lucy.h...@certitude.london

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Jan 28, 2021, 7:06:42 AMJan 28
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Hi Caroline,

I would be very interested in seeing your easy read consent form if it is possible to send it to me,

Thank you very much,

 

Lucy Harrison

 

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Jane Remington-Gurney

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Jan 29, 2021, 3:04:39 AMJan 29
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Hi,
I would also be interested in a copy of the easy read consent form. Thank you in anticipation.
Remingt...@bigpond.com

Best wishes,
Jane🌻

On 28 Jan 2021, at 10:06 pm, lucy.h...@certitude.london wrote:



Mosley, Sally

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Jan 29, 2021, 3:33:56 AMJan 29
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Hi Caroline

 

If you’re happy to share your easy read consent form widely then yes please I would also be very interested to see it.

Sally....@treloar.org.uk

 

Many thanks
Sally

ela robertson

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Jan 29, 2021, 4:32:16 AMJan 29
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I too would be very interested in having a copy of the easy read consent form
many thanks
pam...... el...@btinternet.com
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Steve Naylor

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Jan 29, 2021, 4:37:00 AMJan 29
to 'ela robertson' via CM AAC Forum
Hi Caroline,

Can you count me in too please?


Thanks so much.

Steve

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Gillian Hazell

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Jan 29, 2021, 4:41:43 AMJan 29
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I too would be very interested.

 

Many thanks

 

Gillian

(gil...@aac-consultancy.co.uk)

 

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Dawn Ralph

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Jan 29, 2021, 4:56:35 AMJan 29
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I would also be very interested in the consent form.
Thank you so much
Dawn



Dawn Ralph   

Paediatric Clinical Specialist, Speech & Language Therapist

BSc, MRCSLT, RegHCPC, ASLTIP


​email: dawn....@hotmail.com

​Tel:     07920 025871

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Sent: 29 January 2021 09:38

Deborah Kenchington (MMOM)

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Jan 29, 2021, 6:53:04 AMJan 29
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I would also be interested in having a copy if you are happy to share.  Debbie.ke...@the-aurora-group.com

Many thanks

Debbie

 

Debbie Kenchington

Speech and Language Therapist|Aurora Orchard Manor | The Aurora Group

 

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Sent: 29 January 2021 08:29
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Subject: RE: [External] [AAC Forum] High Tech photo use

 

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Lavender, Mary (Speech And Language Therapy (SALT))

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Feb 2, 2021, 7:23:14 AMFeb 2
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Hi,

I would be interested in the consent form please. Thanks.

 

Mary.l...@cntw.nhs.uk

 

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Frankton Lucy

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Feb 2, 2021, 8:44:38 AMFeb 2
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Hi,

 

Please could I also have a copy of the consent form? Lucy.f...@ghc.nhs.uk

 

Many Thanks,

 

Lucy

 

Lucy Frankton
Highly Specialist Speech and Language Therapist
Gloucestershire Health and Care NHS Foundation Trust

 

Address: North Locality Community Learning Disability Team, Leckhampton Lodge, Charlton Lane, Cheltenham, GL53 9DZ

 

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From: 'Lavender, Mary (Speech And Language Therapy (SALT))' via CM AAC Forum <cm-aac...@googlegroups.com>
Sent: 02 February 2021 12:16
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Subject: RE: [AAC Forum] High Tech photo use

 

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NUTTALL, Sofia (DERBYSHIRE COMMUNITY HEALTH SERVICES NHS FOUNDATION TRUST)

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Feb 3, 2021, 4:33:56 AMFeb 3
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I would be interested too please:

sofia....@nhs.net

 

Thanks

Sofia

 

Sofia Nuttall

Highly Specialist Speech & Language Therapist – AAC Service Lead

Derbyshire Community Health Services Foundation NHS Trust

 

Wednesday/Thursday/Friday

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DIVER, Danielle (BARNSLEY HOSPITAL NHS FOUNDATION TRUST)

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Feb 3, 2021, 5:48:58 AMFeb 3
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Hi, jumping on the band wagon but would also really love to see a copy of this if that’s OK?

d.d...@nhs.net

 

Thanks

Danni

 

Danielle Diver
Assistive Technology Clinical Specialist (Speech and Language Therapist)

Barnsley Assistive Technology Team

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CM Admin

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Feb 3, 2021, 9:20:41 AMFeb 3
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Hi All,

 

Thank you for your interest in this topic.

 

Caroline has kindly shared her easy read consent form with us and it is now available to download from the CM website:

https://www.communicationmatters.org.uk/news/easy-read-consent-form/

 

Kind regards,

Emily Campbell, Charity Manager

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From: cm-aac...@googlegroups.com <cm-aac...@googlegroups.com> On Behalf Of Caroline Fitzgibbon


Sent: 25 January 2021 13:03
To: cm-aac...@googlegroups.com

Subject: RE: [AAC Forum] High Tech photo use

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