Data protection policy
Context and overview
• Policy became operational on 25th May 2018
Pactforsafety.com 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 is 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 Pact for Patient Safety:
• Complies with data protection law and follows good practice
• Protects the rights of staff and users
• Is open about how it stores and processes individuals’ data
• Protects itself from the risks of a data breach
This policy applies to:
• The head office of Pact for Patient Safety
• All staff and volunteers of Pact for Patient Safety
• All contractors, suppliers and other people working on behalf of Pact for Patient Safety
• The website at https://www.pactforsafety.com/
It applies to all data that the company holds relating to identifiable individuals.
This can include:
• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• Any other information relating to individuals
Like most website operators, Pact for Patient Safety collects non-personally identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Pact for Patient Safety’s purpose in collecting non-personally identifying information is to better understand how Pact for Patient Safety’s visitors use its website. From time to time, Pact for Patient Safety may release non-personallyidentifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website. Pact for Patient Safety also collects potentially personally-identifying information like Internet Protocol (IP) addresses for logged in users and for users leaving comments on Pact for Patient Safety blogs, vlogs and posts. Pact for Patient Safety only discloses logged in user and commenter IP addresses under the same circumstances that it uses and discloses personally-identifying information as described below, except that blog commenter IP addresses are visible and disclosed to the administrators of the blog where the comment was left.
Gathering of Personally-Identifying Information
Certain visitors to Pact for Patient Safety’s websites choose to interact with Pact for Patient Safety in ways that require Pact for Patient Safety to gather personally-identifying information. The amount and type of information that Pact for Patient Safety gathers depends on the nature of the interaction. For example, we provide a facility which allows visitors to book an appointment and this information is held securely in our CRM and CMS for the purpose of communications with the customer. Pact for Patient Safety collects such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor’s interaction with Pact for Patient Safety. Pact for Patient Safety does not disclose personally-identifying information other than to comply with the law and visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain website related activities.
From time to time, we may use online advertisers such as Google or Facebook but not limited to these. I order to provide the best experience possible, our website may contain analytics code provided by providers such as Google, LinkedIn and Facebook. By using these services, we transfer nonpersonally identifiable information. Further information available here https://support.google.com/analytics/answer/2700409?hl=en If you wish to opt-out of this, please check out https://tools.google.com/dlpage/gaoptout/
Data protection risks
This policy helps to protect Pact for Patient Safety 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 Pact for Patient Safety 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 team 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.
• Team members 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.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the data controller. (Stephen McMahon).
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.
• Employees 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 and never shared between employees.
• 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 laptops or other mobile devices like tablets or smart phones.
• All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to Family Massage Therapy 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.
• Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external
• Personal data should never be transferred outside of the European Economic Area.
The law requires Pact for Patient Safety 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 Pact for Patient Safety 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.
• Pact for Patient Safety will make it easy for data subjects to update the information Family Massage Therapy 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.
Subject access requests
All individuals who are the subject of personal data held by Pact for Patient Safety 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 email@example.com. The data controller can supply a standard request form, although individuals do not have to use this. The data controller 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, Pact for Patient Safety will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
Pact for Patient Safety 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.