UltraHeal needs to collect and use certain information about individuals. These can include customers, business contacts, suppliers, employees and other people the organization has a relationship with or may need to contact. This policy describes in detail how this personal data must be collected, managed and stored to meet the data protection standards of the company – and to comply with the law.
Why this policy exists
This data protection policy ensures:
- Complies with data protection law and follow good conduct
- Safeguard the rights of staff, customers and partners
- Open about how to store and process the data of individuals
- Protects the organization from the risks of data breach
Data Protection Law
The Data Protection Act 1998 describes how organizations – including UltraHeal – must gather, manage and keep personal information. These rules apply regardless of whether data is stored electronically, on paper or on any other material. To comply with the law, personal data must be gathered and used fairly, stored safely and not disclosed unlawfully.
The Data Protection Act is underpinned by eight significant principles which say personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of the data subjects
- Be protected in proper ways
- 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
This policy applies to:
- The head office of UltraHeal
- All branches of UltraHeal
- All staff and volunteers of UltraHeal
- All contractors, suppliers and other people working on behalf of UltraHeal
It applies to all data or information that the company holds relating to identifiable individuals, even if that data technically falls outside of the Data Protection Act 1998. This can include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- Any other information relating to individuals
Data Protection Risks
This policy helps to protect UltraHeal from some very real data security risks, including:
- Breaches of confidentiality. For example, data being given out inappropriately.
- Failing to offer choice. For instance, all individuals should be free to choose how the company uses information relating to them.
- Reputational damage. For instance, the company could suffer if hackers successfully get access to sensitive data.
Everyone who works for or with UltraHeal has some responsibility for ensuring data is gathered, stored and handled appropriately. Each team that handles personal data must ensure that it is managed and processed in line with this policy and data protection principles. However, these people have key areas of responsibility:
The board of directors is ultimately responsible for ensuring that UltraHeal meets its legal obligations.
The data protection officer is responsible for:
- Keeping the board updated about data protection responsibilities, risks and issues.
- Reviewing all data protection procedures and related policies, in line with an agreed schedule.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data UltraHeal 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.
The IT manager is responsible for:
- Making sure all systems, services and equipment used for storing data meet acceptable security standards.
- 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.
The marketing manager is responsible for:
- Allowing any data protection statements attached to communications such as emails and letters.
- Addressing any data protection queries from journalists or media outlets like newspapers.
- Where necessary, working with other staff to make sure marketing initiatives abide by data protection principles.
General Staff Guidelines
- The only people allowed 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 sensitive information is required, employees can request it from their line managers.
- UltraHeal will offer training to all employees to help them understand their responsibilities when handling data.
- Employees should keep all data secure, by taking reasonable 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 unauthorized 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 needed, it should be deleted and disposed of.
- Employees should request help from their line manager or the data protection officer if they are not sure about any aspect of data protection.
These rules describe how and where data should be safely kept. 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 safe and secure place where unauthorized 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 needed, 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 unauthorized people could see them, like on a printer.
- Data printouts should be shredded and disposed of securely when no longer needed.
When data is stored electronically, it must be protected from unauthorized access, accidental deletion and malicious hacking attempts:
- Data should be protected by strong passwords that are changed frequently and never shared between employees.
- If data is stored on removable media (like a CD or DVD), these should be kept locked away safely when not being used.
- Data should only be stored on designated drives and servers, and should only be uploaded to permitted cloud computing services.
- Servers containing personal data should be sited in a secure and safe 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 methods.
- Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
- All servers and computers having data should be protected by approved security software and a firewall.
Personal data is of no value to UltraHeal unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the biggest 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 safe and secure.
- Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorized external contacts.
Personal data should never be transferred outside of the European Economic Area (EEA).
Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
The law requires UltraHeal to take rational steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is precise, the greater the effort UltraHeal should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take sensible 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 or useless additional data sets.
- Staff should take every opportunity to ensure data is updated. For instance, by verifying a customer’s details when they call.
- UltraHeal will make it easy for data subjects to update the information UltraHeal 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 marketing manager’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 UltraHeal are entitled to:
- Ask what data 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 firstname.lastname@example.org. The data controller can supply a standard request form, although individuals do not need to use this.
The data controller will aim to supply the relevant data within 14 days. The data controller will always verify the identity of anyone trying a subject access request before handing over any data.
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, UltraHeal will disclose requested information. However, the data controller will make sure the request is legitimate, seeking help from the board and from the company’s legal advisers where necessary.
UltraHeal aims to ensure that individuals are aware that their personal data is being processed, and that they understand:
- How the data is being used.
- How to exercise their right.
To these ends, the company has a privacy statement, setting out how your data relating to individuals is used by the company.