Data Protection Policy

GDPR Compliant

• Introduction
• Why This Policy is Needed
• Policy Scope
• Data Protection Risks
• Responsibilities
• General Staff Guidelines
• Data Storage
• Data Use
• Data Accuracy
• Subject Access Requests
• Information Removal Requests
• Disclosing Data for Other Reasons
• Providing Information
• Cookies

Approved by Senior Management on: 23rd May 2018

Policy became operation on: 25th May 2018

Next review date: 29th April 2019

Introduction

Amara Retreats need to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people the company 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 is Needed

The GDPR (General Data Protection Regulation) 2018 describes how organisations – including Amara Retreats 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 GDPR is underpinned by six core principles:

1. Lawfulness, fairness and transparency

Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject.
Lawful: Processing must meet the tests described in GDPR [article 5, clause 1(a)].
Fair: What is processed must match up with how it has been described.
Transparency: Tell the subject what data processing will be done.

2. Purpose limitations

Personal data can only be obtained for “specified, explicit and legitimate purposes” [article 5, clause 1(b)]. Data can only be used for a specific processing purpose that the subject has been made aware of and no other, without further consent.

3. Data minimisation

Data collected on a subject should be “adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed” [article 5, clause 1(c)]. In other words, no more than the minimum amount of data should be kept for specific processing.

4. Accuracy

Data must be “accurate and where necessary kept up to date” [article 5, clause 1(d)]. Baselining ensures good protection and protection against identity theft. Data holders should build rectification processes into data management / archiving activities for subject data.

5. Storage limitations

Regulator expects personal data is “kept in a form which permits identification of data subjects for no longer than necessary” [article 5, clause 1(e)]. In summary, data no longer required should be removed.

6. Integrity and confidentiality

Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

PEOPLE, RISKS AND RESPONSIBILITIES

Policy Scope

This policy applies to:

• The head office of Amara Retreats
• All branches of Amara Retreats
• All staff at Amara Retreats 
• All therapists, contractors, suppliers and other people working on behalf of Amara Retreats

It applies to all data that the companies hold relating to identifiable individuals, even if that information technically falls outside of the GDPR 2018. 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 Amara Retreats from some very real data security risks, including:

• Breaches of confidentiality. For instance, information is 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 Amara Retreats has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and 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.
• Amara Retreats will provide training to all employees to help them understand their responsibilities when handling data.
• Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
• 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 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 Chief Technology Officer or data controller.

When data is stored on paper, it should be kept in a 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 required, the paper or files should be kept in a locked drawer or filing cabinet.
• Employees & contractors should make sure paper and printouts are not left where unauthorized people could see them.
• Data printouts should be shredded and disposed of securely when no longer required.
• By law all client medical notes & records must be kept on file for at least 8 years, financial records for 6 years. At the end of each government financial year (1st April to 31st March), these are archived and locked away for secure storage.
• 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 regularly and never shared between employees.
• If data is stored on removable media (like a CD or DVD, USB memory stick or memory card), 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 mobile devices like tablets or smartphones.
• Mobile laptops that have data stored directly to them, should have a secure password for them and always be locked whenever left unattended. If leaving them for any length of time when not at work, they should be locked away in a secure place.
• 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 Amara Retreats 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, card details & bank account information should never be sent by email, and any other personal data eg health questionnaires should have minimal contact with email, and only when necessary if it cannot be sent in any other way, as this form of communication is not secure.
• Data must be encrypted before being transferred electronically.
• Personal & sensitive data is stored on servers in the UK and 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 Amara Retreats 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 Amara Retreats 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.
• Amara Retreats will make it easy for data subjects to update the information Amara Retreats holds about them. For instance, over the phone, by email or via the company website.
• Data should be updated as inaccuracies are discovered. For instance, if a client 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 Amara Retreats 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 info@amarretreats.com. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will not be charged for subject access requests. The data controller will aim to provide the relevant data within 14 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Information Removal Requests

All individuals who are the subject of personal data held by Amara Retreats are entitled to request that the information that is held about them is removed from the system.

Information removal requests from individuals should be made by email, addressed to the data controller at info@amarretreats.com The data controller can supply a standard request form, although individuals do not have to use this.

The data controller will aim to remove the relevant data within 48hrs.

Disclosing Data for Other Reasons

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

Under these circumstances, Amara Retreats will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the Senior Management team and from the company’s legal advisors where necessary.

Private health records may be shared with appropriate therapists, nurses or doctors, if and when Amara Retreats deems it either necessary or appropriate for the client’s benefit and for best practice.

Providing Information

Amara Retreats 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.

The company privacy statement is available on request, and is also available on the company’s website: www.amararetreats.com

Your Privacy

Your privacy is important to us. To better protect your privacy we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make it available on our homepage and at every point where personally identifiable information may be requested.

Collection of Personal Information

When visiting www.amararetreats.com the IP address used to access the site will be logged along with the dates and times of access. This information is purely used to analyze trends, administer the site, track users movement and gather broad demographic information for internal use. Most importantly, any recorded IP addresses are not linked to personally identifiable information.

Collection & Storage of Your Financial Details

We do not store any of your financial details (credit or debit card numbers) payments are processed by PayPal Virtual Terminal.

Links to third party Websites

We have included links on this site for your use and reference. We are not responsible for the privacy policies on these websites. You should be aware that the privacy policies of these sites may differ from our own.

IP addresses and cookies

We may collect information about your computer, including your IP address, operating system and browser type, for system administration, and to report aggregate information to our advertisers. These are statistical data about our users browsing actions and patterns and do not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file. Cookies are small text files that are placed on your computer by websites that you visit. They therefore contain information that is transferred to your device, such as a computer hard disk or mobile phone.

Cookies help us to improve our site and to deliver a better and more personalized service. They enable us:

• To estimate our audience size and usage pattern
• To store information about your preferences, and so allow us to customize our site according to your individual interests
• To increase the speed of your searches
• To recognize you when you return to our site.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

Our advertisers may also use cookies, over which we have no control.

Our sites produce some cookies which are essential to keep the site working and provide the services you need. These include:

• Cookies that enable you to stay logged in for an entire visit to the site
• Cookies which enable you to add things to a shopping basket and keep them there until you decide to check out.

Cookies which help us improve the site

Some cookies help us to see how people are using our sites. These are known as analytics cookies or tracking cookies. They let us know what areas of website are popular and how people are using the site. This information is anonymous we do not collect anything that would identify a user. We combine this data with the rest of the visitor data and examine it as a whole to build up a picture of how the site is performing. These cookies work only on our site and are not shared.

We also place tiny tags (also known as tracking pixels or web beacons) on some of the emails we send out. These do not collect any personal information either, but they let us know how many people are opening and reading our emails so that we can choose more popular content.

We use cookies to test and improve the quality of our website service. For instance, when we are testing new website content we ask some of our visitors to answer a brief survey. To make sure that we do not ask the same people repeatedly and interfere with their browsing too much, we set a cookie which remembers if they have been asked to participate and what their answers were.

On occasion, we also run multiple versions of a page. Some of our visitors will be shown one version of a page and we then use our analytics to see if this has helped people access more information or experience a better user journey with us. To prevent confusion we set a cookie to make sure that our visitors always see the same version of a page instead of all the different ones.

Cookies which help us get value for money from advertising

We occasionally use other cookies to track how our advertisements perform. As with all our analytics cookies, all the information we collect is anonymous. These cookies are used solely to let us know which site a visitor clicked on for our advertisement, that they have come through to our site and completed whatever action we wished to see promoted such downloading a leaflet or ordering an information pack.

Can I decline to accept cookies?

You are not obliged to accept a cookie that we (or any other web server) send to you. Most browsers accept cookies automatically but you can modify the settings in your browser to turn off this feature. However, cookies are integral to some areas of the website and to certain online services offered by Diabetes Centre, so if you choose not to accept cookies from us, you may not be able to utilise some areas of the website and we may not be able to provide certain online services to you.

Changes to this Privacy Statement

The contents of this statement may be altered at any time, at our discretion.

If you have any questions regarding our privacy policy then you may contact us.