in accordance with the EU General Data Protection Regulation (GDPR)
Context and overview
· Next review date: 25/05/2019
Venn Healthcare needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees 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. Unless we receive specific written instructions to the contrary you agree that we may process this information to fulfil such obligations.
The security of your personal data is important to us and ensures Venn Healthcare conducts the policies on data protection and privacy correctly.
The purpose of this policy is to outline what information we may collect, how we use and secure that information and with whom we may share it. Venn Healthcare is committed to maintaining the highest standards and in doing so, it is necessary to obtain, process, disclose, transfer and store information about our clients. We take these activities seriously and seek to provide fair, secure and appropriate methods that are consistent with both generally accepted privacy ethics and standard business practices, when carrying them out.
By using our website, submitting your Personal Information or using our services, you consent to us using your Personal Information as described below. You also consent to us transferring your Personal Information outside the European Economic Area (“EEA”) where it is done in connection with us providing services to you or where it is necessary for us to fulfil our legal obligations
How does Venn Healthcare use your information? We may use your information for any one or more of the following purposes:
· to confirm your/company’s identity
· to maintain your company profile
· to manage your account and keep you updated on all matters that concern your account
· to provide the services to you that you have requested including processing transactions
· to contact you when necessary or appropriate in relation to the services being provided to you
· to provide you with information about our products and services and provide you with information or opportunities that we believe might be relevant to you
· to tailor the website or other service we provide to you to your needs and interests
· to create anonymised statistical data
If you choose not to have your Personal Information used to support Venn Healthcare’s customer relationship programmes (especially direct-marketing or market-research), we will respect your choice. Venn Healthcare does not now (and does not intend to in the future) sell, rent or otherwise market your Personal Information to third parties, other than as anonymised statistical data. You may opt out of receiving marketing emails at any time by selecting the 'unsubscribe' link at the top of the emails or by contacting our Customer Services with your request. However, we must still send you notices about changes to the Venn Healthcare Terms and Conditions and other important matters concerning the operation of your account.
Why this policy exists
This date protection policy ensures Venn Healthcare:
· Complies with data protection law and follow good practice
· Protects the rights of staff, 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 Venn Healthcare
- 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 states 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
This policy applies to:
· The head office of Venn Healthcare
· All branches of Venn Healthcare
· All staff and volunteers of Venn Healthcare
· All contractors, suppliers and other people working on behalf of Venn Healthcare
It applies to all data that the company holds relating to identifiable individuals, even of 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 Venn Healthcare 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.
Everyone who works for or with Venn Healthcare 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 if for their work.
· Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
· Venn Healthcare 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.
· 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 management if they are unsure about any aspect of data protection.
The law requires Venn Healthcare to take reasonable steps to ensure data is kept accurate and up to date.
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.
· 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.
Subject access requests
All individuals who are the subject of personal data held by Venn Healthcare 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.
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, Venn Healthcare will disclose requested date. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.