Data Protection policy for Verity Howard, Teacher and Therapist of Body & Sole.
Policy prepared by: Verity Howard trading as Body&Sole (VH) · Next review date: 15/4/2019
In order to operate, VH needs to gather, store and use certain forms of information about individuals. These can include adult students and clients and business contacts and other people that VH has a relationship with or regularly needs to contact. This policy explains how this data is collected, stored and used in order to comply with the General Data Protection Regulations (GDPR).
Why is this policy important? This policy ensures that VH:
Protects the rights of students and clients, complies with data protection law and follows good practice and protects from the risks of a data breach
Who and what does this policy apply to?
It applies to all data that VH holds relating to individuals, including: Names, Email addresses, Postal addresses, Phone numbers, Medical information and any other personal information held.
Roles and responsibilities
VH is the Data Controller and will determine what data is collected and how it is used. She is responsible for the secure, fair and transparent collection and use of data. VH uses third party Data Processors (Google Drive) to process data on its behalf. VH will ensure all Data Processors are compliant with GDPR. VH to also hold medical records and personal information in paper form held in a secure locked location.
DATA PROTECTION PRINCIPLES
a. I fairly and lawfully process personal data in a transparent way. VH will only collect data where lawful and where it is necessary for the legitimate purposes of her teaching and therapy business. An individual's name, contact details and other details may be collected at any time, with their consent, in order for VH to communicate with them and promote classes and products.
b. I only collect and use personal data for specific, explicit and legitimate purposes and will only use the data for those specified purposes.
When collecting data, VH will always provide a clear and specific privacy statement explaining to the subject why the data is required and what it will be used for.
c. I ensure any data collected is relevant and not excessive
VH will not collect or store more data than the minimum information required for her intended purpose.
d. I ensure data is accurate and up-to-date
VH will ask current students and clients to provide current email addresses and contact number which will be updated annually. students and clients will also be able to update their data at any point by contacting VH.
e. I ensure data is not kept longer than necessary
VH will keep records for no longer than is necessary in order to meet the intended use for which it was gathered (unless there is a legal requirement to keep records). The storage and intended use of data will be reviewed in line with VH's data retention policy. When the intended use is no longer applicable (e.g medical records for pregnancy 25 years and all other medical records up to 7 years), after the stated peroid the data will be deleted within a reasonable period.
f. I keep personal data secure
VH will ensure that data held is kept secure.
Electronically-held data will be held within a password-protected and secure environment Physically-held data will be stored on a locked cupboard
g.Transfer to countries outside the EEA VH will not transfer data to countries outside the European Economic Area (EEA), unless the country has adequate protection for the individual's data privacy rights.
When VH collects, holds and uses an individual's personal data that individual has the following the rights over that data. VH will ensure her data processes comply with those rights and will make all reasonable efforts to fulfil requests from an individual in relation to those rights.
Right to be informed: whenever VH collects data she will provide a clear and specific privacy statement explaining why it is being collected and how it will be used.
Right of access: individuals can request to see the data VH holds on them and confirmation of how it is being used. Requests should be made in writing to VH and will be complied with free of charge and within one month. Where requests are complex or numerous this may be extended to two months
Right to rectification: individuals can request that their data be updated where it is inaccurate or incomplete. Right to object: individuals can object to their data being used for a particular purpose. VH will always provide a way for an individual to withdraw consent in all marketing communications. Where VH receives a request to stop using data she will comply unless she has a lawful reason to use the data for legitimate interests or contractual obligation. Right to erasure: individuals can request for all data held on them to be deleted. VH's data retention policy will ensure data is not held for longer than is reasonably necessary in relation to the purpose it was originally collected.
If a request for deletion is made she will comply with the request unless: There is a lawful reason to keep and use the data for legitimate interests or contractual obligation. There is a legal requirement to keep the data.
Right to restrict processing: individuals can request that their personal data be 'restricted' - that is, retained and stored but not processed further (e.g. if they have contested the accuracy of any of their data, VH will restrict the data while it is verified).
Data retention policy
This policy sets out how VH will approach data retention and establishes processes to ensure data is not held for longer than is necessary. It forms part of VH's Data Protection Policy.
Roles and responsibilities
VH is the Data Controller and will determine what data is collected, retained and how it is used. She is responsible for the secure and fair retention and use of data. A regular review of all data will take place to establish if VH still has good reason to keep and use the data held at the time of the review.
As a general rule a data review will be held every 2 years and no more than 27 calendar months after the last review. The first review took place on 15th April 2018.
Data to be reviewed
Digital documents (e.g. spreadsheets) stored on personal devices
Data stored on third party online services e.g. Google Drive. The review will be conducted by VH.
How data will be deleted
Physical data will be destroyed safely and securely, including shredding.
All reasonable and practical efforts will be made to remove data stored digitally.
Priority will be given to any instances where data is stored in active lists (e.g. where it could be used) and to sensitive data.
Where deleting the data would mean deleting other data that VH has a valid lawful reason to keep (e.g. on old emails) then the data may be retained safely and securely but not used.
Date stored by VH may be retained based in statutory requirements for storing data other than data protection regulations.
This might include but is not limited to:
Details of payments made and received (e.g. in bank statements and accounting records)
Contracts and agreements with suppliers/customers
Mailing list data
If an individual opts out of a mailing list their data will be removed as soon as is practically possible.
All other data will be stored safely and securely and reviewed as part of the next two year review