Privacy notice
1. About this privacy notice
Mulberry Tree Specialist Infant Feeding Support respects your privacy and is committed to protecting your personal information.
This privacy notice explains what information I collect about you and your baby, why I need it, how I use and protect it, when I may share it, how long I keep it and the rights you have under UK data protection law.
For the purposes of UK data protection law, Laura Rodgers trading as Mulberry Tree Specialist Infant Feeding Support is the data controller.
Mulberry Tree provides specialist infant feeding support through home visits, telephone consultations and online consultations.
2. Contact details
Laura Rodgers
Mulberry Tree Specialist Infant Feeding Support
Infant Feeding Specialist (IBCLC), NMC Registered Nurse and Health Visitor
Website: www.mulberry-tree.co.uk
Email: laura@mulberry-tree.co.uk
You can contact me using the details above if you have any questions about this notice or how your personal information is handled.
3. Information I collect
To provide safe and appropriate infant feeding support, I may collect information about both the parent or carer and the baby.
Personal and contact information
- name
- address
- date of birth
- telephone number
- email address
- details needed to arrange appointments and communicate with you
Website enquiries
If you submit the website enquiry form, your contact details, selected enquiry topic and any optional brief message are sent to me by email so I can respond and discuss possible next steps. Please keep the optional message brief and leave out health or clinical details about you or your baby. If you arrange a service, your enquiry may become part of business correspondence.
Information about your baby
- name
- date of birth
- birth and pregnancy information where relevant
- feeding history
- growth or weight information where relevant
- relevant health and developmental information
Health and clinical information
- current and previous feeding difficulties
- breastfeeding, bottle feeding, combination feeding, expressing, formula feeding or introducing solids
- relevant medical history
- medications where relevant
- symptoms affecting feeding
- breast and nipple symptoms
- assessment findings
- oral function assessment
- observations made during a consultation
- lactation-related conditions assessed within my professional competence
- feeding plans and recommendations
- follow-up information
- information about referrals or onward advice
Health information is classed as special category personal data and receives additional protection under data protection law.
4. Photographs and videos
Where clinically useful, you may choose to send photographs or videos, for example to help assess feeding, positioning, oral function or a breast or nipple concern.
Clinically relevant photographs or videos may form part of the clinical record.
Where material is received through WhatsApp Business or another communication service, clinically relevant material may be transferred into the secure client record. Unnecessary duplicate copies will not be retained longer than needed.
Photographs and videos will not be used for advertising, social media, teaching, case studies or testimonials without separate, specific permission.
5. Why I use your information
- arrange and manage consultations
- identify clients correctly
- understand your concerns and feeding goals
- assess infant feeding
- provide appropriate professional advice and support
- undertake clinical assessments within my professional competence
- prepare feeding plans and consultation summaries
- monitor progress and provide follow-up support
- maintain appropriate professional clinical records
- communicate with other healthcare professionals where appropriate
- identify situations where further medical or professional assessment may be required
- meet safeguarding responsibilities
- respond appropriately in an emergency
- manage complaints or legal claims
- issue invoices, receive payments and maintain financial and tax records
- meet my professional, regulatory and legal obligations
I only collect information that is reasonably necessary for these purposes.
6. My lawful basis for using your information
UK data protection law requires me to have a lawful reason for processing personal information.
Providing consultations and infant feeding services
For information necessary to arrange and provide the service you have requested, I generally rely on:
Article 6(1)(b) UK GDPR - Contract
This is because the information is needed to provide the consultation or other service you have asked Mulberry Tree to provide.
Website enquiries
If you contact me through the website to ask about support or a possible appointment, I use the details you provide to respond, discuss whether support may be suitable and, if you choose to proceed, arrange next steps. This is processing at your request before a contract is made, so I rely on Article 6(1)(b) UK GDPR.
Health and clinical information
Health information requires an additional condition under UK GDPR.
For health information used in connection with infant feeding assessment, clinical records, feeding plans and healthcare support, I generally rely on:
Article 9(2)(h) UK GDPR - provision of health or social care
Laura Rodgers is an NMC Registered Nurse and Health Visitor and an International Board Certified Lactation Consultant (IBCLC), and processes clinical information subject to professional duties of confidentiality.
This allows Mulberry Tree to maintain appropriate clinical records and provide healthcare without relying on data-protection consent as the basis for every item of clinical information.
This is separate from clinical consent. You will still be involved in decisions about assessment, support and care.
Financial and tax information
Where records must be retained to comply with tax, accounting or other legal requirements, I rely on:
Article 6(1)(c) UK GDPR - Legal obligation
Complaints and legal claims
Information may need to be retained or used to investigate a complaint, respond to a claim or protect legal rights.
Depending on the circumstances, I may rely on Article 6(1)(f) - Legitimate interests and, where health information is involved, Article 9(2)(f) - establishment, exercise or defence of legal claims.
Safeguarding
There may be circumstances in which information needs to be used or shared to protect a child or vulnerable person.
Where applicable, Mulberry Tree may rely on the lawful provisions available for safeguarding and protecting vulnerable individuals under UK data protection law.
Where it is safe and appropriate to do so, I will normally discuss concerns and proposed information sharing with you. There are circumstances where information may need to be shared without consent.
Emergencies
In a genuine emergency where a person's life or physical safety is at serious risk, information may be used or shared where necessary to protect their vital interests.
7. Who I may share information with
I treat clinical information as confidential.
Where appropriate and necessary, information may be shared with healthcare or other professionals involved in the care of you or your baby. This could include:
- your GP
- midwife
- health visitor
- NHS infant feeding services
- tongue-tie assessment services
- other relevant healthcare professionals
- NHS 111, urgent care or emergency services where appropriate
For routine communication with another healthcare professional, I would normally discuss this with you and obtain your agreement.
Information may be shared without consent where there is a lawful and necessary reason to do so, including serious safeguarding concerns, legal obligations or genuine emergencies.
Only information that is relevant and necessary will be shared.
8. Organisations that help provide the service
Mulberry Tree uses a small number of technology and service providers to operate the business. These may include:
- Apple, including iCloud and FaceTime
- WhatsApp Business / Meta
- 123-reg and cPanel-based email services
- Starling Bank
- providers used for secure backup, website hosting or technical services
These organisations may process limited personal information when providing their services.
Some technology providers may process or store information outside the UK. Where this happens, appropriate protections required by UK data protection law will be relied upon.
9. WhatsApp Business, SMS and email
You may communicate with Mulberry Tree through WhatsApp Business, telephone, SMS or email.
Although reasonable security measures are used, electronic communications are not completely without risk.
WhatsApp Business is used on a dedicated Mulberry Tree business device. Clinically important information received through messaging may be transferred into the clinical record where appropriate.
You should avoid sending unnecessary sensitive information through messaging services.
10. How your information is stored and protected
Clinical information is stored electronically using dedicated Mulberry Tree business equipment.
Measures used to protect information include:
- dedicated Mulberry Tree Mac and mobile phone
- device passcodes
- full-disk encryption
- multi-factor authentication where available
- current security updates
- access controls
- secure iCloud storage
- encrypted backup arrangements
- separation of clinical records from general business and financial records
Clinical records use a unique Mulberry Tree client reference rather than relying on client names in filenames and folder structures.
There are no routine paper clinical records.
Technical guidance may be provided by Pete Rodgers, but he does not have routine access to identifiable client or clinical information.
Website and enquiry form
The form uses a short-lived, essential session cookie for security and spam prevention. The website does not store enquiry submissions in a database and does not currently use analytics or advertising cookies. The hosting provider may create technical server logs as part of operating the website.
11. How long I keep information
Mulberry Tree keeps personal information only for as long as there is a justified professional, legal or business need to do so.
Clinical records
Clinical records relating to infant feeding care will normally be retained until the child's 25th birthday.
This retention period has been selected with reference to established UK health-record retention guidance for children's and health-visiting records and reflects the need to maintain appropriate records for:
- professional accountability
- continuity and review of care
- safeguarding
- handling future complaints
- responding to possible legal claims
- meeting professional and insurance requirements
Clinical records may include:
- consultation notes
- feeding assessments
- oral function assessments
- feeding plans
- clinically relevant photographs or videos
- correspondence forming part of the clinical record
- referrals or communications with other healthcare professionals
- consent and safeguarding information where relevant
Records will be securely deleted when the applicable retention period expires unless there is a specific legal, safeguarding, clinical, professional or insurance reason that justifies retaining them for longer.
Information not forming part of the clinical record
Information that does not need to form part of the permanent clinical record will normally be deleted sooner. For example:
- duplicate WhatsApp messages
- duplicate photographs or videos
- temporary administrative notes
- unsuccessful enquiries where no consultation takes place
Such information will be deleted when it is no longer reasonably needed for the purpose for which it was collected.
Financial and tax records
Financial, invoice and tax records will be retained for at least the period required by HM Revenue & Customs and other applicable legal requirements.
12. Your data protection rights
Depending on the circumstances and the lawful basis being used, you may have rights including:
- the right to be informed about how your information is used
- the right to request access to personal information held about you
- the right to ask for inaccurate information to be corrected
- the right to ask for incomplete information to be completed
- the right to request deletion of information in certain circumstances
- the right to request restriction of processing in certain circumstances
- the right to object to certain types of processing
- the right to data portability where applicable
These rights are not absolute.
For example, a request to delete information does not necessarily mean that a clinical record can immediately be destroyed. There may be professional, legal, safeguarding or insurance reasons why some information must continue to be retained.
Where information about your baby is held, you may normally exercise relevant rights on their behalf where you have parental responsibility and it is appropriate to do so.
If you would like to exercise a data protection right, please contact Mulberry Tree using the contact details in this notice.
13. Automated decision-making
Mulberry Tree does not use automated decision-making or profiling to make clinical decisions about clients.
Clinical assessments and recommendations are made by Laura Rodgers using professional judgement.
14. Marketing, testimonials and case studies
Clinical information is not used for marketing purposes.
Mulberry Tree will not publish an identifiable client testimonial, photograph, video or case study without obtaining separate and specific permission.
Choosing not to provide such permission will have no effect on the care or service you receive.
15. Safeguarding and confidentiality
Confidentiality is an important part of the relationship between Mulberry Tree and its clients. However, confidentiality is not absolute.
Information may need to be shared where Laura reasonably believes that:
- a child or vulnerable person may be at risk of harm
- there is a serious risk to someone's health or safety
- disclosure is required by law
- information is required in connection with legal proceedings
- emergency services need information to protect life or physical safety
Any disclosure will be limited to information considered necessary and appropriate in the circumstances.
16. Making a data protection complaint
If you have a concern about how Mulberry Tree has collected, stored, used or shared your information, please contact Laura first so the concern can be investigated.
Laura Rodgers
Mulberry Tree Specialist Infant Feeding Support
Email: laura@mulberry-tree.co.uk
You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data protection regulator.
Information about making a complaint is available at www.ico.org.uk.
ICO telephone helpline: 0303 123 1113
17. Changes to this notice
This privacy notice will be reviewed regularly and updated where necessary.
If Mulberry Tree makes a significant change to the way personal information is collected or used, the privacy information provided to clients will be updated before the new processing begins.
The current version will always be available at www.mulberry-tree.co.uk.