Data Protection Policy
Context and overview
• Policy prepared by: Sally Tapping
• Policy became operational on: 25/05/2018
• Next review / audit date: 25/05/2021
Movement Perfected needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees and other people the clinic
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.
Why this policy exists
This data protection policy ensures Movement Perfected:
• Complies with data protection law and follow good practice
• Protects the rights of staff, customers and partners
• Is open about how it stores and processes individuals’ data
• Protects itself from the risks of a data breach
Data protection law
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) describes how organisations — including 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 Data Protection Act is underpinned by seven important principles. These say that personal
a) processed lawfully, fairly and in a transparent manner in relation to individuals;
b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and f) 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. g) Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
People, risks and responsibilities
This policy applies to:
• The premises of Movement Perfected
• All staff and volunteers of Movement Perfected
• All contractors, suppliers and other people working on behalf of Movement Perfected
It applies to all data that the company holds relating to identifiable individuals, even if that
information technically falls outside of the General Data Protection Regulation. This can include:
• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• Plus any other information relating to individuals
Data protection risks
This policy helps to protect Movement Perfected from some 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 Movement Perfected has some responsibility for ensuring data is
collected, stored and handled appropriately.
Each person that handles personal data must ensure that it is handled and processed in line with
this policy and data protection principles.
However, these people have key areas of responsibility:
• The director Chris Pettit ultimately responsible for ensuring that Movement Perfected meets
its legal obligations.
• A Data protection officer has not been appointed on the basis that data processing is small
scale, and therefore a DPO is not legally required. These responsibilities will be therefore
the requirement of the Data Contoller.
• Keeping the staff updated about data protection responsibilities, risks and issues.
• Reviewing all data protection procedures and related policies, in line with an agreed
• 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
• Dealing with requests from individuals to see the data Movement Perfected holds
about them (also called ‘subject access requests’).
• Checking and approving any contracts or agreements with third parties that may
handle the company’s sensitive data.
• Ensuring all systems, services and equipment used for storing data meet acceptable
• Performing regular checks and scans to ensure security hardware and software is
• Evaluating any third-party services the company is considering using to store or
process data. For instance, cloud computing services.
• Approving any data protection statements attached to communications such as
emails and letters.
• Addressing any data protection queries from journalists or media outlets like
• Where necessary, working with other staff to ensure marketing initiatives abide by
data protection principles.
• Performing a formal data protection audit every 3 years, or if poor data protection
practices is noticed by any member of staff and brought to the attention of the
General staff guidelines
• The only people able to access data covered by this policy should be those who need it for
• Data should not be shared informally.
• Movement Perfected will provide training when needed to all employees, to help them
understand their responsibilities when handling data.
• Employees should keep all data secure, by taking sensible precautions and following the
• In particular, passwords must be used for all data and these should never be shared with
anyone who does not require data access.
• When sharing or communicating data, this must be done with consent from the person
who’s data we hold. Any data transferred must be anonymised or password protected or
sent by encrypted email
• Personal data should not be disclosed to unauthorised people, either within the company or
• 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.
• Employees should request help from the data protection controller if they are unsure about
any aspect of data protection.
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.
• Data printouts should be shredded or incinerated and disposed of securely when no longer
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 and only shared with employees that require
access for their core work.
• All letter templates must be either be irreversibly anonymised, or password protected.
• If data is stored on removable media (like a CD or DVD), these should be kept locked away
securely when not being used.
• 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.
• 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
• All servers and computers containing data should be protected by approved security
software and a firewall.
Personal data is of no value to Movement Perfected 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 emails addresses must be
confirmed prior to sending, potential mistakes can make this form of communication
insecure. You may consider email encryption for particularly sensitive data.
• Personal data should never be transferred outside of the European Economic Area.
• Employees should not save copies of personal data to their own computers. Always access
and update the central copy of any data.
The law requires Movement Perfected to take reasonable steps to ensure data is kept accurate and
up to date.
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.
• 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.
• 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
Subject access requests
All individuals who are the subject of personal data held by [company name] 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.
• Patients have the right to data deletion, the right to be forgotten. Currently adult patient
data is required to be held for 8 years following their last appointment. For patients under
18 years of age the file must be held until 26 years of age and a minimum of 8 years from
the last appointment
If an individual contacts the company requesting this information, this is called a subject access
Subject access requests from individuals should be made in writing with written and signed
consent. The data controller can supply a standard request form, although individuals do not have
to use this.
Individuals will not be charged to view their data. The data controller will always verify the identity
of anyone making a subject access request before handing over any information.
If a data request is denied for any reason this must be provided in writing to the subject together
with information on how to make a complaint to the information commissioner.
Disclosing data for other reasons
In certain circumstances, GDPR allows personal data to be disclosed to law enforcement agencies
without the consent of the data subject, or where there is a risk to life.
Under these circumstances, Movement Perfected 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.
Movement Perfected 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.