Session Recording and Transcription Policy

Remarkable Minds introduces families, schools and local authorities to vetted specialists who support neurodivergent children. Much of that support is delivered as one-to-one online video sessions, often with a child in their own home and an adult they have never met before.

We want to be explicit about this, because the word “recording” makes people picture something we do not do: we do not currently make video or audio recordings of sessions. Recording is switched off in the video platform. Nothing is filmed, and no audio file is created, kept or stored.

What we do create is a written transcript of what is said in an online session. This policy explains what that transcript contains, why we make it, who can read it, how long we keep it and what rights the people in it have. It applies to everyone who takes part in an online session: children and young people, parents and carers, specialists and tutors, and any Remarkable Minds staff member who joins.

Remarkable Minds does not carry out assessments or diagnosis and is not a clinic or a healthcare provider. A transcript is a record of a support session, not a clinical record.

We do not record video or audio. There is no video file, no audio file, no screen capture and no photograph of any session. Nobody at Remarkable Minds can watch or listen back to a session, because there is nothing to watch or listen to.

We do create a transcript. When a session runs on the Remarkable Minds video platform, speech is converted to text live, as the session happens, and the text is saved. That covers sessions you join through a Remarkable Minds joining link, which means booked online sessions with a specialist and free video consultations with us. Transcription starts automatically when the specialist or host joins, so it is not something an individual has to remember to switch on.

What is stored for each session:

• The words spoken, as text
• A speaker label for each line, which is the display name the person joined under, or simply “Specialist” or “Parent” where no name is available
• The time each line was spoken
• Which session the transcript belongs to, and when that session started and ended

What is not transcribed:

• In-home tutoring sessions. Nothing at all is captured when a tutor works in a family home: no recording, no transcript, no filming and no photographs
• Telephone calls between a specialist and a family
• Anything happening in your home outside the session itself
• Anything shared on screen, and the in-session chat, neither of which is saved

A transcript is machine-generated, so it will contain mistakes. Speech-to-text misreads names, accents, overlapping voices and unfamiliar words. A transcript is a useful record, not a verbatim account, and we treat it that way when we read one.

Nobody makes their own recording. Specialists are contractually prohibited from recording, screen capturing, photographing or separately transcribing a session, including with artificial intelligence note-takers. Families and children must not record either. If you record a session without our agreement you become responsible under data protection law for what you have made, and we may end the booking.

We transcribe online sessions for three reasons and no others.

• Safeguarding. If a concern is raised about what happened in a session, a transcript means there is a contemporaneous record rather than two conflicting memories. It protects children from harm, and it protects specialists from unfounded allegations.
• Quality. We look at a small number of sessions to check that specialists are working to our standards and within their scope of practice, particularly early in a specialist’s time with us.
• Session write-up. A specialist who is not writing notes is a specialist who is actually with the child. The transcript means they can be present in the session and still produce an accurate plan and write-up afterwards.

A transcript is also the record we use where a complaint or a billing dispute turns on what was said, so that we can resolve it fairly.

We do not use transcripts for marketing, for advertising, for training artificial intelligence models, for automated decision-making about a child, or to profile anyone. We do not sell them and we do not share them with any organisation for commercial purposes.

For the transcript itself, our lawful basis under Article 6 of the UK GDPR is legitimate interests, Article 6(1)(f): our interest, and the interest of every family we work with, in delivering online sessions to children safely and in being able to answer questions about what happened in a session. We have carried out a balancing assessment. We limit what is captured (text only, never video or audio), who can read it and how long we keep it, and we are satisfied that the interests of the people transcribed are protected by those limits.

A transcript of a session about a neurodivergent child will inevitably reveal information about health or disability, which is special-category data under Article 9. For that aspect, and for any safeguarding use of a transcript, we rely on the substantial public interest condition in Article 9(2)(g) together with the condition for safeguarding of children and of individuals at risk at paragraph 18 of Part 2 of Schedule 1 to the Data Protection Act 2018. That condition applies where processing is necessary to protect a person under 18, or an adult at risk, from neglect or physical, mental or emotional harm, and where seeking consent would prejudice that protection.

Specialists and tutors additionally agree to transcription contractually, through the Specialist and Tutor Agreement, because the transcript includes what they personally say. Their acceptance is recorded against a version and a date. Withdrawing that agreement means they can no longer deliver online sessions through the platform; it does not, by itself, delete transcripts already made for safeguarding purposes.

Nobody should ever be surprised to learn a session was transcribed. We tell people at each of these points:

• At the point of booking, in the booking confirmation and in the terms the client accepts
• In the joining email sent before the session
• In our privacy policy and on this page
• For specialists, in the agreement they accept before their first booking

We also ask specialists to say out loud at the start of the first session with a child that what is said is being written down, in language the child can understand, and to answer any question a child has about it. A child is entitled to know a record is being made and to be told who might read it.

You can ask for transcription to be turned off for a session. To be honest about how this works: there is no setting in your account that you control. You ask us, or you ask the specialist, before the session starts, and we switch it off for that session. Asking during the session is too late to stop what has already been captured, though we can stop it there and delete what exists. We will not ask you to justify the request, and it will not affect the support you receive. If a specific safeguarding reason means we think a session should be transcribed, we will tell you that and explain why, rather than doing it quietly.

Access is restricted to named Remarkable Minds staff on a need-to-know basis. In practice that is our Designated Safeguarding Lead, Jake Owen, and a small number of named staff with a quality or complaint-handling role. Transcripts are held in an internal administration area that requires a separate staff login, and nobody outside that small group can reach it.

A transcript is only opened where there is a reason connected to one of the purposes in section 3, and the person opening it reads only the part they need.

Who cannot read a transcript:

• Other families, other children, or anyone else using the platform
• Other specialists and tutors
• The specialist who delivered the session, who has no transcript access in the platform and must ask us for the record of their own session
• Our staff generally. There is no browsing access to transcripts from an ordinary account
• Any advertiser, data broker, marketing partner or artificial intelligence provider
• A school, employer or local authority that funded the session, unless a safeguarding or legal obligation requires disclosure and it is proportionate to make it

Our video, transcription and hosting suppliers process this data on our instructions only, under written contracts that meet Article 28 of the UK GDPR. They cannot use it for their own purposes.

We keep a transcript for 90 days after the session, and then delete it. Deleting it removes every line of it, not just the link to the session.

There is one exception. Where a safeguarding concern, a complaint, a regulatory enquiry or a legal claim is raised that relates to a session, we preserve the transcript before the 90 days expire. A preserved transcript is kept until that matter is concluded, and then for as long as the resulting record has to be kept under safeguarding record-keeping practice, our insurers’ requirements or the law. We record why each transcript was preserved and review those decisions at least annually so that nothing is kept indefinitely by accident.

Backups roll off on their own cycle, which may hold a copy for a short period after deletion from the live system. Backup copies are encrypted, are not accessible for day-to-day use, and are overwritten in the ordinary course.

Transcripts are encrypted in transit and encrypted at rest. They are held in the United Kingdom or the European Economic Area. Where a supplier processes data outside that area, we put an approved transfer mechanism in place, such as the UK International Data Transfer Agreement or the UK Addendum to the European Commission standard contractual clauses.

Transcripts sit behind a staff-only login, are not indexed, are not linked from any public page and are not reachable by guessing an address. Accounts with access use strong, unique credentials, and access is removed the day a person’s role changes. Because no video or audio exists, the amount of personal data at risk in the event of a breach is materially smaller than it would otherwise be, which is one of the reasons recording stays switched off.

We may disclose a transcript, or part of one, to the police, to a local authority children’s social care team or Multi-Agency Safeguarding Hub, to a Local Authority Designated Officer, to the Disclosure and Barring Service, to a professional regulator, or to a court, where we are required to do so by law or where it is necessary to protect a child or an adult at risk.

Any disclosure is decided by the Designated Safeguarding Lead, limited to what is necessary, and recorded with the reason, the recipient, the legal basis and the date. We say clearly, when we hand a transcript over, that it is machine-generated and may contain errors.

We will normally tell the people in a transcript that a disclosure has been made. We may not be able to tell you in advance, or at all, where doing so would prejudice the prevention or detection of crime, the apprehension or prosecution of offenders, a safeguarding enquiry, or where a police officer or social worker asks us not to. This reflects the exemptions in Schedule 2 to the Data Protection Act 2018.

Everyone who appears in a transcript has rights over it. A parent or carer can usually exercise a younger child’s rights on their behalf; an older child who understands what they are asking for can exercise their own.

• Access. You can ask for a copy of a transcript of a session you took part in. We respond within one month. A transcript almost always contains other people’s personal data, so we may need to redact parts of it. Where we cannot separate the data fairly, we will explain why.
• Objection. Because we rely on legitimate interests, you can object to your sessions being transcribed. Tell us and we will act on it for future sessions, as described in section 5.
• Erasure. You can ask us to delete a transcript early. We will do it unless we need to keep it for a live safeguarding concern, complaint or legal claim, or where the law requires us to keep it. Everything else is deleted at 90 days in any case.
• Rectification and restriction. Because a transcript is machine-generated, it may get words wrong. You can ask us to correct it or to add your account of what was actually said alongside it, and you can ask us to restrict what we do with a transcript while a dispute is being resolved.

The limits are worth stating plainly. We cannot give you a transcript that has already been deleted, and we cannot give you video or audio, because none exists. Where a transcript is being held for a safeguarding matter, we may not be able to delete it or to show it to you while that matter is live.

To exercise any of these, email hello@remarkableminds.app with the date and time of the session and who was in it, so we can find the right transcript before it is deleted. Please do not delay, because we cannot retrieve a transcript once it has gone.

We may decide in future that recording video or audio is justified. If that happens, we will not do it quietly. We will update this policy and publish a new version, tell everyone affected before the first recorded session takes place, and ask specialists to accept the new version of the Specialist and Tutor Agreement before it applies to them.

Until you have been told otherwise, you can take this page at face value: no video or audio recording is made of any session.

If you are unhappy with how a transcript has been made, used, shared or deleted, tell us first at complaints@remarkableminds.app and we will handle it under our complaints policy. If your concern is about a child’s safety, it goes to the Designated Safeguarding Lead at jake@remarkableminds.app instead, and is dealt with under our safeguarding policy.

You do not have to come to us first, and you can complain to the Information Commissioner's Office at any time about how we have handled personal data. The ICO can be reached at www.ico.org.uk or on 0303 123 1113.

This policy is owned by the Designated Safeguarding Lead and approved by the directors of Remarkable Minds Ltd. It is reviewed at least annually, and sooner if the way we deliver sessions changes, if our suppliers change, or if guidance from the Information Commissioner's Office changes.