Purpose of policy
This privacy notice applies to information we collect from individuals including clients, suppliers, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data will be collected, handled and stored to comply with the UK General Data Protection Regulation (GDPR).
Policy statement
We are committed to a policy of protecting the rights and privacy of clients, staff and others in accordance with UK General Data Protection Regulation, committing to:
- Comply with both the law and good practice
- Respect individuals’ rights
- Be open and honest with individuals whose data is held
- Provide training and support to staff who handle personal data, so that they can act confidently and consistently
- Register their details with the Information Commissioner’s Office (ICO)
Personal data
We may hold data for the following purposes:
- Provision of direct healthcare
- Marketing and newsletters
- Case histories
- Staff administration
Special categories of data included race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health and sexual orientation.
We may hold special category data for the following purposes:
- Provision of direct healthcare
Data protection principles
There are six data protection principles that are core to the UK General Data Protection Regulation. We will make every possible effort to comply with these principles at all times in their information-handling practices. The principles are:
1. Lawful, fair and transparent
Data collection must be fair, for a legal purpose and they must be open and transparent as to how the data will be used.
2. Limited for its purpose
Data can only be collected for a specific purpose.
3. Data minimisation
Any data collected must be necessary and not excessive for its purpose.
4. Accurate
The data we hold must be accurate and kept up to date.
5. Retention
We cannot store data longer than necessary.
6. Integrity and confidentiality
The data we hold must be kept safe and secure.
7. Key risks
The main risks are in two key areas:
- Information about individuals getting into the wrong hands, through poor security or inappropriate disclosure of information.
- Individuals being harmed through data being inaccurate or insufficient.
Responsibilities
We are responsible for:
- Analysing and documenting the type of personal data we hold
- Checking procedures to ensure they cover all the rights of the individual
- Identifying the lawful basis for processing data
- Ensuring consent procedures are lawful
- Implementing and reviewing procedures to detect, report and investigate personal data breaches
- Storing data in safe and secure ways
- Assessing the risk that could be posed to individual rights and freedoms should data be compromised
Data recording, security and storage
1. Data accuracy and relevance
We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.
2. Data security
We will keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, we will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.
3. Storing data securely
- In cases when data is stored on printed paper, it will be kept in a secure place where unauthorised personnel cannot access it
- Printed data will be shredded when it is no longer needed
- Data stored on a computer will be protected by strong passwords that are changed regularly. A password manager will be used to create and store passwords
- Cloud services used to store personal data will be assessed for compliance with UK GDPR principles. An authenticator app will be used to access cloud data
- Servers containing personal data must be kept in a secure location, away from general office space
- Data will be regularly backed up
- All servers containing sensitive data must be protected by security software
- All possible technical measures will be put in place to keep data secure
4. Data retention
We will retain personal data for no longer than is necessary. This shall be in accordance with the guidelines of our professional association, BANT.
5. Accountability and transparency
We will ensure accountability and transparency in all our use of personal data. We will keep written up-to-date records of all the data processing activities that we do and ensure that they comply with each of the UK GDPR principles.
We will regularly review our data processing activities and implement measures to ensure privacy by design including data minimisation, pseudonymisation, transparency and continuously improving security and enhanced privacy procedures.
6. Consent
We will ensure that consents are specific, informed and plain English such that individuals clearly understand why their information will be collected, who it will be shared with, and the possible consequences of them agreeing or refusing the proposed use of the data. Consents will be granular to provide choice as to which data will be collected and for what purpose. We will seek explicit consent wherever possible.
We will maintain an audit trail of consent by documenting details of consent received including who consented, when, how, what, if and when they withdraw consent. We will regularly review consents and seek to refresh them regularly or if anything changes.
7. Direct marketing
We will comply with both data protection law and Privacy and Electronic Communication Regulations 2003 (PECR) when sending electronic marketing messages. PECR restricts the circumstances in which we can market people and other organisations by phone, text, email or other electronic means.
We will seek explicit consent for direct marketing. We will provide a simple way to opt out of marketing messages and be able to respond to any complaints.
If you have any queries about your data privacy or our use of your information please contact:
Kat Chan
hello@katchan.co