The Injury Clinic

White Cottage

Hadham Cross

Much Hadham

Hertfordshire

SG11 6AL

 

Data protection policy

Context and overview

Key details

• Policy prepared by:                           Alice Findlay

• Approved by Kirsty on:                      04/05/18    

• Policy became operational on:         May 2019    

• Next review date:                               May 2019        

Introduction

The Injury Clinic needs to gather and use certain information about individuals.

These can include clients, business contacts, workshop participants 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 The Injury Clinic:

• Complies with data protection law and follows good practice 

• Protects the rights of staff and clients

• 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 The Injury Clinic— 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

8. 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:

• White Cottage, Hadham Cross, Much Hadham, SG10 6AL

• Other sites that therapists work from

• All staff and volunteers of The Injury Clinic

• All contractors, suppliers and other people working on behalf of The Injury Clinic

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

• Details of treatment carried out

• Assessment of condition

• …plus any other information relating to individuals

Data protection risks

This policy helps to protect The Injury Clinic from 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 The Injury Clinic has some responsibility for ensuring data is collected, stored and handled appropriately.

Each person that 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:

• Kirsty Baldock is ultimately responsible for ensuring that The Injury Clinic meets its legal obligations.

• Processors, Kirsty Baldock, Giles Gamble, Nicola Pittman and Alice FIndlay, are responsible for:

  • Keeping each other updated about data protection responsibilities, risks and issues.

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

  • Handling data protection questions from clients and anyone else covered by this policy.

  • Dealing with requests from individuals to see the data The Injury Clinic 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.

  • Ensuring 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.

• Kirsty Baldock is responsible for:

  • Approving 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 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.

• Employees should keep all data secure, by taking sensible precautions and following the guidelines below.

• In particular, strong passwords must be used.

• 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.

 

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.

• We 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.

• 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, approved mobile phones and tablets and should only be uploaded to an approved cloud computing services.

• Designated drives/servers:

  • Main Laptop and removable hard drive

  • Giles Gamble, Kirsty Baldock, Nicola Pittman and Alice Findlay’s Mobile phones (only contact details will be stored on mobiles)

  • All other devices that access data (including Alice’s IPad) will not store data locally, and only access data though the cloud.

• Data should be backed up frequently. Those backups should be tested regularly.

 

Data use

Personal data is of no value to The Injury Clinic 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.

• Personal data should never be transferred outside of the European Economic Area.

• We should not save copies of personal data to any computer or tablets other than the main work laptop. Always access and update the central copy of any data.

 

Data accuracy

The law requires The Injury Clinic 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 The Injury Clinic should put into ensuring its accuracy.

It is the responsibility of all 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.

• 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.

 

 

Subject access requests

All individuals who are the subject of personal data held by The Injury Clinic 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 Kirsty Baldock (theinjuryclinic.kb@gmail.com).

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

Kirsty 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, The Injury Clinic will disclose requested data. However, Kirsty Baldock will ensure the request is legitimate.

 

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hs                                                            Session                        Security            

incap_ses_${Proxy-ID}_${Site-ID}       Session                        Security          

incap_visid_${Proxy-ID}_${Site-ID}     Session                        Security             

nlbi_{ID}                                         Persistent cookie                Security           

XSRF-TOKEN                                  Persistent cookie               Security            

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