Approved by Senior Management on: 23rd May 2018
Policy became operation on: 25th May 2018
Next review date: 29th April 2019
Anamchara Retreats Ltd (UK) & Amchara Ltd (Malta) need to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people the company 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.
The GDPR (General Data Protection Regulation) 2018 describes how organisations – including Anamchara Retreats Ltd & Amchara Ltd – 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 GDPR is underpinned by six core principles:
1. Lawfulness, fairness and transparency
Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject.
Lawful: Processing must meet the tests described in GDPR [article 5, clause 1(a)].
Fair: What is processed must match up with how it has been described.
Transparency: Tell the subject what data processing will be done.
2. Purpose limitations
Personal data can only be obtained for “specified, explicit and legitimate purposes” [article 5, clause 1(b)]. Data can only be used for a specific processing purpose that the subject has been made aware of and no other, without further consent.
3. Data minimisation
Data collected on a subject should be “adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed” [article 5, clause 1(c)]. In other words, no more than the minimum amount of data should be kept for specific processing.
Data must be “accurate and where necessary kept up to date” [article 5, clause 1(d)]. Baselining ensures good protection and protection against identity theft. Data holders should build rectification processes into data management / archiving activities for subject data.
5. Storage limitations
Regulator expects personal data is “kept in a form which permits identification of data subjects for no longer than necessary” [article 5, clause 1(e)]. In summary, data no longer required should be removed.
6. Integrity and confidentiality
Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
PEOPLE, RISKS AND RESPONSIBILITIES
This policy applies to:
It applies to all data that the companies hold relating to identifiable individuals, even if that information technically falls outside of the GDPR 2018. This can include:
This policy helps to protect Anamchara Retreats Ltd & Amchara Ltd from some very real data security risks, including:
Everyone who works for or with Anamchara Retreats Ltd & Amchara Ltd 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.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Chief Technology Officer or data controller.
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:
Personal data is of no value to Anamchara Retreats Ltd / Amchara Ltd 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:
The law requires Anamchara Retreats Ltd / Amchara Ltd 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 Anamchara Retreats Ltd / Amchara Ltd should put into ensuring its accuracy.
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.
All individuals who are the subject of personal data held by Anamchara Retreats Ltd / Amchara Ltd are entitled to:
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 protected] The data controller can supply a standard request form, although individuals do not have to use this.
Individuals will not be charged for subject access requests. The data controller will aim to provide the relevant data within 14 days.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.
All individuals who are the subject of personal data held by Anamchara Retreats Ltd / Amchara Ltd are entitled to request that the information that is held about them is removed from the system.
Information removal requests from individuals should be made by email, addressed to the data controller at [email protected] The data controller can supply a standard request form, although individuals do not have to use this.
The data controller will aim to remove the relevant data within 48hrs.
In certain circumstances, the GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Anamchara Retreats Ltd / Amchara Ltd will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the Senior Management team and from the company’s legal advisors where necessary.
Private health records, may be shared with appropriate therapists, nurses or doctors, if and when Amchara deem it either necessary or appropriate for the client’s benefit and for best practice.
Anamchara Retreats Ltd / Amchara Ltd aims to ensure that individuals are aware that their data is being processed, and that they understand:
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.
The company privacy statement is available on request, and is also available on the company’s website: www.amchara.com/privacy.
We may collect information about your computer, including your IP address, operating system and browser type, for system administration, and to report aggregate information to our advertisers. These are statistical data about our users browsing actions and patterns, and do not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file. Cookies are small text files that are placed on your computer by websites that you visit. They therefore contain information that is transferred to your device, such as computer hard disk or mobile phone.
Cookies help us to improve our site and to deliver a better and more personalised service. They enable us:
Our sites produce some cookies which are essential to keep the site working and provide the services you need. These include:
Some cookies help us to see how people are using our sites. These are known as analytics cookies or tracking cookies. They let us know what areas of website are popular and how people are using the site. This information is anonymous we do not collect anything that would identify a user. We combine this data with the rest of the visitor data and examine it as a whole to build up a picture of how the site is performing. These cookies work only on our site and are not shared.
We also place tiny tags (also known as tracking pixels or web beacons) on some of the emails we send out. These do not collect any personal information either, but they let us know how many people are opening and reading our emails so that we can choose more popular content.
On occasion, we also run multiple versions of a page. Some of our visitors will be shown one version of a page and we then use our analytics to see if this has helped people access more information or experience a better user journey with us. To prevent confusion we set a cookie to make sure that our visitors always see the same version of a page instead of all the different ones.
We occasionally use other cookies to track how our advertisements perform. As with all our analytics cookies, all the information we collect is anonymous. These cookies are used solely to let us know which site a visitor clicked on for our advertisement, that they have come through to our site and completed whatever action we wished to see promoted such downloading a leaflet or ordering an information pack.
You are not obliged to accept a cookie that we (or any other web server) send to you. Most browsers accept cookies automatically but you can modify the settings in your browser to turn off this feature. However, cookies are integral to some areas of the website and to certain online services offered by Diabetes Centre, so if you choose not to accept cookies from us, you may not be able to utilise some areas of the website and we may not be able to provide certain online services to you.
The contents of this statement may be altered at any time, at our discretion.