GDPR Policy

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Data protection policy

Context and overview

Key details

• Policy      prepared by: Alexandra      Hayward
• Policy became      operational on: 1/11/2019.  

· Next review date: 1/11/2022 

Introduction

ASH Healthcare Training (ASH HCT) needs to gather and use certain information about individuals.

These can include clients, learners, suppliers, business contacts, freelance trainers and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures ASH HCT:

· Complies with data protection law and follow good practice 

· Protects the rights of freelance trainers, learners, customers and partners

· Is open about how it stores and processes individuals’ data

• Protects      itself from the risks of a data breach

Data protection law

The Data Protection Act 1998 describes how organisations — including ASH HCT— must collect, handle and store personal information. 

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

1. Be processed fairly and lawfully

2. Be obtained only for specific, lawful purposes

3. Be adequate, relevant and not excessive

4. Be accurate and kept up to date

5. Not be held for any longer than necessary

6. Processed in accordance with the rights of data subjects

7. Be protected in appropriate ways

1. Not      be transferred outside the European Economic Area (EEA), unless that      country or territory also ensures an adequate level of protection

People, risks and responsibilities

Policy scope

This policy applies to:

· The head office of ASH HCT

· All staff and volunteers of ASH HCT

• All      contractors, suppliers and other people working on behalf of ASH HCT

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

· Names of individuals

· Postal addresses

· Email addresses

· Telephone numbers

• …plus      any other information relating to individuals

Data protection risks

This policy helps to protect ASH HCTfrom some very real data security risks, including:

· Breaches of confidentiality. For instance, information being given out inappropriately.

· Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.

• Reputational damage. For      instance, the company could suffer if hackers successfully gained access      to sensitive data.

Responsibilities

Everyone who works for or with ASH HCT has some responsibility for ensuring data is collected, stored and handled appropriately.

Each person whom handles personal data must ensure that it is handled and processed in line with this policy and data protection principles. 

However, these people have key areas of responsibility:

• The      owner is ultimately responsible      for ensuring that ASH HCT meets its legal obligations and is      responsible for:

o Keeping updated about data protection responsibilities, risks and issues.

o Reviewing all data protection procedures and related policies, in line with an agreed schedule.

o Arranging data protection training and advice for the people covered by this policy.

o Handling data protection questions from anyone covered by this policy.

o Dealing with requests from individuals to see the data ASH HCT holds about them (also called ‘subject access requests’).

• Checking       and approving any contracts or agreements with third parties that may       handle the company’s sensitive data.
• and:

o Ensuring all systems, services and equipment used for storing data meet acceptable security standards.

o Performing regular checks and scans to ensure security hardware and software is functioning properly.

• Evaluating       any third-party services the company is considering using to store or       process data. For instance, cloud computing services.
• and:

o Approving any data protection statements attached to communications such as emails and letters.

o Addressing any data protection queries from journalists or media outlets like newspapers.

• Where       necessary, working with other staff to ensure marketing initiatives abide       by data protection principles.

General staff guidelines

• The      only people able to access data covered by this policy should be those who      need it for their work.
• Data      should not be shared informally.      When access to confidential information is required, employees can request      it from their line managers.
• ASH HCT will provide training to      all employees to help them understand their responsibilities when handling      data.
• Employees      / consultants / freelancers should keep all data secure, by taking      sensible precautions and following the guidelines below.
• In      particular, strong passwords must      be used and they should never be shared.
• Personal      data should not be disclosed to      unauthorised people, either within the company or externally.
• Data      should be regularly reviewed and      updated if it is found to be out of date. If no longer required, it      should be deleted and disposed of.
• Employees      should request help from their      line manager or the data protection officer if they are unsure about any      aspect of data protection. 

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

• When      not required, the paper or files should be kept in a locked drawer or filing cabinet.
• Employees      should make sure paper and printouts are not left where unauthorised people could see them, like on a      printer.
• Data printouts should be shredded and      disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

• Data      should be protected by strong      passwords that are changed regularly and never shared between      employees.
• If      data is stored on removable media (like      a CD or DVD), these should be kept locked away securely when not being      used.
• Data      should only be stored on designated      drives and servers, and should only be uploaded to an approved cloud computing services.
• Servers      containing personal data should be sited      in a secure location, away from general office space.
• Data      should be backed up frequently.      Those backups should be tested regularly, in line with the company’s      standard backup procedures.
• Data      should never be saved directly to      laptops or other mobile devices like tablets or smart phones.
• All      servers and computers containing data should be protected by approved security software and a firewall.

Data use

Personal data is of no value to ASH HCT unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

• When      working with personal data, employees should ensure the screens of their computers are always locked when left      unattended.
• Personal      data should not be shared      informally. In particular, it should never be sent by email, as this      form of communication is not secure.
• Data      must be encrypted before being transferred      electronically. The IT manager can explain how to send data to      authorised external contacts.
• Personal      data should never be transferred      outside of the European Economic Area.
• Employees      should not save copies of personal      data to their own computers. Always access and update the central copy      of any data.

Data accuracy

The law requires ASH HCT to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort ASH HCT should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible. 

• Data      will be held in as few places as      necessary. Staff should not create any unnecessary additional data      sets.
• Staff      should take every opportunity to ensure      data is updated. For instance, by confirming a customer’s details when      they call.
• ASH      HCT will make it easy      for data subjects to update the information ASH HCT holds about      them. For instance, via the company website.
• Data      should be updated as inaccuracies      are discovered. For instance, if a customer can no longer be reached      on their stored telephone number, it should be removed from the database.
• It      is the Alexandra Hayward’s responsibility to ensure marketing databases are checked against industry suppression      files every six months.

Subject access requests

All individuals who are the subject of personal data held by ASH HCT are entitled to:

• Ask what information the company holds about them and why.
• Ask how to gain access to it.
• Be informed how to keep it up to date. 
• Be informed how the company is meeting its data protection      obligations.

If an individual contacts the company requesting this information, this is called a subject access request. 

Subject access requests from individuals should be made by email, addressed to the data controller at [email address]. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 per subject access request. ASH HCT will aim to provide the relevant data within 14 days.

ASH HCT will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, ASH HCTwill disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Providing information

ASH HCT aims to ensure that individuals are aware that their data is being processed, and that they understand:

• How      the data is being used
• How      to exercise their rights 

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.

[This is available on request.]