Christine Horner is currently working on a number of other projects including writing a new book and updating previous books.
When you contact the Clinic, if any health advice is required, this will be forwarded to Julia Davies and her team.
DATA SECURITY POLICY
Issue 2: 14th October 2019
Contents
Margaret Hills Clinic needs to gather and use certain information about individuals.
These can include patients, customers, suppliers, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data will be collected, handled and stored to comply with the General Data Protection Regulations.
Margaret Hills Clinic is committed to a policy of protecting the rights and privacy of patients, customers, staff and others in accordance with General Data Protection Regulations.
Margaret Hills Clinic commits to:
Margaret Hills Clinic may hold data for the following purposes:
Special categories of data include race, ethnic origin, genetics, biometrics (where used for ID purposes), health and sexual orientation. Margaret Hills Clinic may hold special category data for the following purposes:
1.4 Data Protection Principles
There are six data protection principles that are core to the General Data Protection Regulation. Margaret Hills Clinic will make every possible effort to comply with these principles at all times in our information-handling practices. The principles are:
The main risks are in two key areas:
Tracey Hudson, Company Secretary, is responsible for all personal data held by us and is responsible for:
3.1 Data Accuracy and Relevance
Margaret Hills Clinic will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.
Margaret Hills Clinic will keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, we will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.
Margaret Hills Clinic will retain personal data for no longer than is necessary.
Margaret Hills Clinic will ensure accountability and transparency in all our use of personal data. We will keep written up-to-date records of all the data processing activities that we do and ensure that they comply with each of the GDPR principles.
We will regularly review our data processing activities and implement measures to ensure privacy by design including data minimisation, transparency and continuously improving security and enhanced privacy procedures.
Margaret Hills Clinic will ensure that consents are specific, informed and clear such that individuals fully understand why their information will be collected, who it will be shared with, and the possible consequences of them agreeing or refusing the proposed use of the data. Consents will be itemised to provide choice as to which data will be collected and for what purpose.
We will maintain an audit trail of consent by documenting details of consent received including who consented, when, how, what, if and when they withdraw consent.
We will regularly review consents and seek to refresh them regularly or if anything changes.
Note that Margaret Hills Clinic will share data with Julia Davies Nutrition for the purposes of provision of health related advice.
Margaret Hills Clinic will comply with both data protection law and Privacy and Electronic Communication Regulations 2003 (PECR) when sending electronic marketing messages. PECR restricts the circumstances in which we can contact people and other organisations by phone, text, email or other electronic means.
We will seek explicit consent for direct marketing. We will provide a simple way to opt out of marketing messages and be able to respond to any complaints.
7.1 What is a Subject Access Request?
An individual has the right to receive confirmation that their data is being processed, access to their personal data and supplementary information, i.e. information which should be provided in a privacy notice.
7.2 How to Deal with Subject Access requests
Margaret Hills Clinic will provide an individual with a copy of the information requested, free of charge. This will occur within one month of receipt of the request. We endeavour to provide data subjects access to their information in commonly used electronic formats (as described in section 4.3)
If complying with the request is complex or onerous, the deadline can be extended by two months, but the individual will be informed within one month.
We can refuse to respond to certain requests and can, in circumstances of the request being manifestly unfounded or excessive, charge a fee. If the request is for a large quantity of data we can request the individual specify the information they are requesting.
Once a Subject Access Request has been made, we will not change or amend any of the data that has been requested; doing so is a criminal offence.
7.3. Data Portability Requests
We will provide the data requested in a structured, commonly used and machine-readable format. This would normally be a PDF file, although other formats are acceptable. We must provide this data either to the individual who has requested it or to the data controller they have requested it be sent to within one month.
There are restrictions in international transfers of personal data. We will not transfer personal data abroad without express consent.
9.1 Using Third Party Controllers and Processors
As a data controller and/or data processor, we will have written contracts in place with any third-party data controllers (and/or) data processors that we use. The contract will contain specific clauses which set out our and their liabilities, obligations and responsibilities.
As a data controller, we will only appoint processors who can provide sufficient guarantees under GDPR that the rights of data subjects will be respected and protected. Julia Davies Nutrition is a data processor and Margaret Hills Clinic are satisfied that appropriate systems are in place to protect our patients' data.
As a data processor, we will only act on the documented instructions of a controller. We acknowledge our responsibilities as a data processor under GDPR and we will protect and respect the rights of data subjects.
Our contract will comply with the standards set out by the ICO and where possible follow standard contractual clauses. Our contracts with data controllers (and/or) data processors will set out the subject matter and duration of the processing, the nature and stated purpose of the processing activities, the types of personal data and categories of data subject, and the obligations and rights of the controller.
Any breach of this policy or of data protection laws will be reported as soon as practically possible. This means as soon as we become aware of a breach.
Margaret Hills Clinic has a legal obligation to report any data breaches to the UK Supervisory authority which is the Information Commissioners Officer within 72 hours.
If you have any questions or comments in relation to this policy, please contact Tracey Hudson, Company Secretary at the Clinic on 01926 353131 or email [email protected]
