Data Protection Policy
We hold personal data about our employees, clients, suppliers and other individuals for a variety of business purposes.
This policy sets out how we seek to protect personal data and ensure that staff understands the rules governing their use of personal data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.
The purposes for which personal data may be used by us, personnel, administrative, financial, regulatory, payroll, and business development purposes.
Business purposes include the following:
– Compliance with our legal, regulatory and corporate governance obligations and good practice
– Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests
– Ensuring business policies are adhered to (such as policies covering email and internet use)
– Operational reasons, such as recording transactions, training, and quality control, ensuring the confidentiality of commercially sensitive information, security vetting, credit scoring and checking
– Investigating complaints
– Checking references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration, and assessments
– Monitoring staff conduct, disciplinary matters
– Marketing our business
– Improving services
Information relating to identifiable individuals, such as job applicants, current and former employees, agency, contract and other staff, clients, suppliers, and marketing contacts.
Personal data we gather may include: individuals’ contact details, educational background, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, job title, and CV.
Sensitive personal data
Personal data about an individual’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offenses, or related proceedings—any use of sensitive personal data is strictly controlled in accordance with this policy.
This policy applies to all staff. You must be familiar with this policy and comply with its terms.
This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.
Who is responsible for this policy?
As our Data Protection Officer, Katharina Nyilas, has overall responsibility for the day-to-day implementation of this policy.
Fair and lawful processing
We process personal data fairly and lawfully in accordance with individuals’ rights. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening.
The Data Protection Officer’s responsibilities:
• Keeping the board updated about data protection responsibilities, risks, and issues
• Reviewing all data protection procedures and policies on a regular basis
• Arranging data protection training and advice for all staff members and those included in this policy
• Answering questions on data protection from staff, board members, and other stakeholders
• Responding to individuals such as clients and employees who wish to know which data is being held on them by Medico Digital
• Checking and approving with third parties that handle the company’s data any contracts or agreement regarding data processing
• Approving data protection statements attached to emails and other marketing copy
• Addressing data protection queries from clients, target audiences or media outlets
• Coordinating with the DPO to ensure all marketing initiatives adhere to data protection laws and the company’s Data Protection Policy
Responsibilities of the IT Manager
• Ensure all systems, services, software and equipment meet acceptable security standards
• Checking and scanning security hardware and software regularly to ensure it is functioning properly
• Researching third-party services, such as cloud services the company is considering using to store or process data
The processing of all data must be:
• Necessary to deliver our services
• In our legitimate interests and not unduly prejudice the individual’s privacy
• In most cases this provision will apply to routine business data processing activities.
Our Terms of Business contains a Privacy Notice to clients on data protection
• Sets out the purposes for which we hold personal data on customers and employees
• Highlights that our work may require us to give information to third parties such as expert witnesses and other professional advisers
• Provides that customers have a right of access to the personal data that we hold about them
Subject access requests
Please note that under the Data Protection Act 1998, individuals are entitled, subject to certain exceptions, to request access to information held about them.
If you receive a subject access request, you should refer that request immediately to the DPO. We may ask you to help us comply with those requests.
Please contact the Data Protection Officer if you would like to correct or request information that we hold about you. There are also restrictions on the information to which you are entitled under applicable law.
Processing data in accordance with the individual’s rights
You should abide by any request from an individual not to use their personal data for direct marketing purposes and notify the DPO about any such request.
Do not send direct marketing material to someone electronically (e.g. via email) unless you have an existing business relationship with them in relation to the services being marketed.
Please contact the DPO for advice on direct marketing before starting any new direct marketing activity.
All staff will receive training on this policy. New joiners will receive training as part of the induction process. Further training will be provided at least every two years or whenever there is a substantial change in the law or our policy and procedure.