UK GDPR · HCPC Standards of Proficiency · Data Protection Act 2018
Patient Data and Records Policy
How we create, maintain, protect, and retain your clinical records — and your rights in relation to them
Last reviewed: April 2026
Records custodian: Stephen Fairfield HCPC HAD00366
Next review due: April 2027
Why We Keep Clinical Records
HCPC Standards of Proficiency require all registered audiologists to keep accurate, contemporaneous, and complete records of their clinical practice. Clinical records serve multiple important purposes:
- They enable continuity of care across all appointments and clinicians
- They provide the reference point for monitoring changes in your hearing over time
- They evidence the clinical basis for all treatment decisions, including hearing aid prescriptions
- They protect both you and your audiologist in the event of a clinical dispute
- They enable us to meet our legal and regulatory obligations
What Records We Hold
- Personal and contact details (name, date of birth, address, telephone, email, GP details)
- Medical and medication history relevant to hearing health
- Audiograms, speech discrimination scores, tympanograms, and all other test results
- Otoscopy findings and images where recorded
- Clinical notes from all appointments
- Hearing aid prescription data, device settings, and fitting records
- Ear wax removal records
- Tinnitus and balance assessment records and management plans
- Referral letters and clinical correspondence with GPs, ENT consultants, and other healthcare providers
- Correspondence with you relating to your care
- Financial records relating to your treatment
How Long We Keep Your Records
| Patient category |
Retention period |
Standard applied |
| Adult patients (18 and over at last contact) |
8 years from the date of last clinical contact |
HCPC guidance / NHS records management code (adopted as best practice) / Limitation Act 1980 |
| Children and young people (under 18 at last contact) |
Until the patient’s 25th birthday, or 8 years from last contact – whichever is longer |
NHS records management code (best practice) |
| Patients who die within the retention period |
8 years from the date of death |
HCPC guidance |
| Industrial hearing damage / medico-legal records |
As instructed by the instructing party, plus 12 years |
Limitation Act 1973 (Scotland) – personal injury limitation period |
How We Store and Protect Your Records
- Digital records: Secure, password-protected, UK-based practice management software with access restricted to authorised clinical and administrative staff. Regular encrypted backups.
- Paper records: Locked filing systems within our clinics, accessible only to authorised staff. Clinics are secured outside opening hours.
- Email: Clinical information is not transmitted by unencrypted email unless you have explicitly accepted this method and the associated risks.
- Access controls: Only staff directly involved in your care and administrators with a legitimate need have access to your records. All such staff are bound by professional confidentiality obligations under HCPC standards.
Accessing Your Records – Subject Access Requests
You have the right under UK GDPR Article 15 to request a copy of the personal data we hold about you. We will:
- Respond within one calendar month of receiving a valid request
- Provide information in PDF or paper format on request
- Not charge for the first copy of your records (subsequent requests in a 12-month period may incur a reasonable administrative fee)
- Provide records in an accessible format (large print, simplified summary) on request
How to make a Subject Access Request
Email [email protected] or write to either clinic address, clearly marked FAO Data Protection – Subject Access Request. We may need to verify your identity before releasing records.
Correcting Inaccurate Records
If you believe any information in your clinical records is inaccurate, please contact us. Corrections are made by amendment note (with the date and reason for amendment) rather than deletion of the original entry, to maintain clinical integrity. You may add a statement to your records where a factual dispute cannot be resolved.
Destruction of Records
- Paper records are cross-cut shredded using a certified confidential waste service
- Digital records are deleted using secure deletion processes that prevent recovery
- A destruction record is maintained
Transferring Your Records
If you move to another audiology practice, we will transfer a copy of your clinical records to your new provider at no charge within one calendar month of written request. We retain a copy for the full retention period regardless of any transfer.