1 Introduction

1.1 Purpose of Policy

Viva Natural Health needs to gather and use certain information about individuals.

These can include clients, 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 Regulation.

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Policy Statement

Natural Health is committed to a policy of protecting the rights and privacy of clients, and others in accordance with General Data Protection Regulation.

Natural Health commits to:

comply with both the law and good practice
respect individuals’ rights
be open and honest with individuals whose data is held
Register our details with the Information Commissioner’s Office (ICO)

Personal Data

Natural Health may hold data for the following purposes:

Provision of direct healthcare Marketing and newsletters Case histories

Special categories of data included race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health and sexual orientation.

Viva Natural Health may hold special category data for the following purposes: - Provision of direct healthcare

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Data Protection Principles

There are six data protection principles that are core to the General Data Protection Regulation. Viva Natural Health will make every possible effort to comply with these principles at all times in our information-handling practices. The principles are:

1. 1)  Lawful, fair and transparent

   Data collection must be fair, for a legal purpose and we must be open and

   transparent as to how the data will be used.

2. 2)  Limited for its purpose

   Data can only be collected for a specific purpose.

3. 3)  Data minimisation

   Any data collected must be necessary and not excessive for its purpose.

4) Accurate

The data we hold must be accurate and kept up to date.

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5) Retention

We cannot store data longer than necessary.

6) Integrity and confidentiality

The data we hold must be kept safe and secure.

Key risks

The main risks are in two key areas:

•   information about individuals getting into the wrong hands, through poor security or inappropriate disclosure of information

•   individuals being harmed through data being inaccurate or insufficient 2 Responsibilities

  Viva Natural Health is the data controller for all personal data held by us and is responsible for:

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• Analysing and documenting the type of personal data we hold

• Checking procedures to ensure they cover all the rights of the individual

• Identifying the lawful basis for processing data

• Ensuring consent procedures are lawful

• Implementing and reviewing procedures to detect, report and investigate

  personal data breaches

• Storing data in safe and secure ways

• Assessing the risk that could be posed to individual rights and freedoms should

  data be compromised

  Data Recording, Security and Storage Data accuracy and relevance

Viva Natural Health 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.

3.2 Data security

Viva Natural Health 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.

3.3 Storing data securely

In cases when data is stored on printed paper, it will be kept in a secure place where unauthorised personnel cannot access it
Software used to store/handle data will also comply with GDPR regulations Printed data will be shredded when it is no longer needed

Data stored on a computer will be protected by strong passwords that are changed regularly. A password manager will be used to create and store passwords.

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Data stored on CDs or memory sticks will be encrypted or password protected and locked away securely when they are not being used
Cloud services used to store personal data will be assessed for compliance with GDPR principles. An authenticator app will be used to access cloud data. Servers containing personal data must be kept in a secure location, away from general office space

Data will be regularly backed up.
All servers containing sensitive data must be protected by security software All possible technical measures will be put in place to keep data secure Data retention

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accordance with the guidelines of our professional association, BANT.

Natural Health will retain personal data for no longer than is necessary. This shall be in

4 Accountability and Transparency

Viva Natural Health 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, pseudonymisation, transparency and continuously improving security and enhanced privacy procedures.

5 Consent

Viva Natural Health will ensure that consents are specific, informed and plain English such that individuals clearly 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 granular to provide choice as to which data will be collected and for what purpose. We will seek explicit consent wherever possible.

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. For online consent, we may use a cryptographic hash function to support data integrity. Alternatively we will maintain the consents information in a spreadsheet with links to the consent forms.

We will regularly review consents and seek to refresh them regularly or if anything changes.

6 Direct Marketing

Viva Natural Health 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 market 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.