Policy document for Data protection GDPR for Holistic Coach
Context and Overview
Policy prepared by Paulo da Costa. The nature of Data Processing does not require registration with the Information Commissioner’s Office (ICO). Policy became operational on the 22nd of October 2019.
Holistic Coach needs to gather and use certain information about individuals. This can include client contact details including phone numbers, home address, email address, health information, GP’s name and practice, medication.
Why this policy exists:
This data protection policy ensures Holistic Coach:
- complies with data protection law and follows good practice
- protects the rights of staff, clients and partners
- is open about how it stores and processes individuals’ data
itself from the risks of data breach
Data Protection Law
5th May 2018 General Data Protection Regulation (GDPR) legislation comes into effect.
GDPR replaces Data Protection Act 1998. It describes how organisations – including Holistic Coach must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or 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 is underpinned by eight important principles. These say that personal data must:
• be processed fairly and lawfully
• be obtained only for specific lawful purposes
• be adequate, relevant and not excessive
• be accurate and kept up to date
• not be held for longer than necessary
• processed in accordance with the rights of data subjects
• be protected in appropriate ways
• not be transferred outside the European Economic Area (EEA), unless the country or territory also ensures an adequate level of protection.
The policy applies to:
Holistic Coach and therapists working within its service provision
It applies to all data relating to identifiable individuals, even if that information technically falls outside the Data Protection Act 1998, and includes:
• names of individual clients and contacts
• postal addresses
• email addresses
• telephone numbers
• health information relevant to the clients presenting symptoms
• Gp’s name and practice
• Medication and drug use
• case notes taken before and during therapy / coaching including dates attended and payments received.
• Information supplied by the client which is relevant to therapy / coaching
Data protection risks
This policy helps to protect Holistic Coach 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.
Everyone who works for Holistic Coach has some responsibility for ensuring data is collected stored and handled appropriately. All personal data must be handled and processed in line with this policy and data protection principles.
Paulo da Costa is responsible for ensuring that Holistic Coach meets its legal obligations which include:
• keeping updated about data protection responsibilities risks and issues
• reviewing all data protection procedures and related policies
• arranging data protection training and advice for the people covered by this policy
• handling data protection questions from staff and anyone else covered by this policy
• dealing with requests from individuals to see the data Holistic Coach holds about them (subject access requests)
• checking and approving any involvement with third parties that may handle the sensitive data
General Staff guidelines
- the only people able to access data covered by this policy should be those who need it for their work
- data must not be shared informally
- Holistic Coach will keep all data secure
- data stored on computer will be password protected
- personal data will 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
These rules describe how and where data should be safely stored
• When data is stored on paper it should be kept in a secure place where unauthorised people cannot see it. All the data will be store electronically
• These guidelines also apply to data that is usually stored electronically but has been printed out for some reason
• when not required the paper of files should be kept in a locked drawer of filing cabinet
• personal documents must not be left where unauthorized 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 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 CD or DVD these should be kept locked away securely when not being used
• data should only be stored on designated drives and computers and should only be uploaded to an approved cloud computing services
• drives containing personal data should be sited in a secured location
• data should be backed up frequently. Those backups should be tested
• 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 value to Holistic Coach unless it is necessary for the provision of the service. 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 it is important to ensure the screens of their computers are always locked when left unattended.
• Personal data should not be shared informally. In particular it should not be sent by email as this form of communication is not secure
• personal data should never be transferred outside the service
Subject access requests
• all individuals who are the subject of personal data held by Holistic Coach 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 an email address. The data controller can supply a standard request form although individuals do not have to use this. The data controller will aim to provide the relevant data within 14 days.
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 Holistic Coach will disclose requested data. However Holistic Coach will ensure the request is legitimate, seeking assistance from the appropriate professional body when necessary.
Holistic Coach 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