Internal Data Protection Policy

GDPR Compliant

This Data Protection Policy covers:

Policy Start date - 25th May 2018

Policy Review date - 29th April 2019

Policy Last Updated date - 24th May 2018

Introduction

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.

Why This Policy is Needed

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.

4. Accuracy

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

Policy Scope

This policy applies to:

  • The head office of Anamchara Retreats Ltd & Amchara Ltd
  • All branches of Anamchara Retreats Ltd & Amchara Ltd
  • All staff at Anamchara Retreats Ltd & Amchara Ltd
  • All contractors, suppliers and other people working on behalf of Anamchara Retreats Ltd & Amchara Ltd

    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:

    • Names of individuals
    • Postal addresses
    • Email addresses
    • Telephone numbers
    • …plus any other information relating to individuals

    Data Protection Risks

    This policy helps to protect Anamchara Retreats Ltd & Amchara Ltd from 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.

    Responsibilities

    Everyone who works for or with Anamchara Retreats Ltd & Amchara Ltd has some responsibility for ensuring data is collected, stored and handled appropriately and if they handle personal data, then they must ensure that it is handled and processed in line with this policy and data protection principles.

    General Staff Guidelines

    • The only people able to access data covered by this policy should be those who need it for their work
    • Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
    • Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
    • Personal data should not be disclosed to unauthorised 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.
    • Employees should request help from their line manager if they are unsure about any aspect of data protection.

    Intellectual Property

    All Amchara intellectual property and any related material you are given access to in order to fulfil your job role will remain the sole property of Amchara and may not be used for any purposes outside that of your employment role with Amchara, nor may it be copied or edited and used for any other business or purpose during your contract or beyond the end of your contract term.

    Any work you are asked to produce or develop during your employment term will remain the intellectual property of Amchara and Amchara will not be restricted in its usage in any manner.

    Data Storage

    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.

    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.
    • Employees & contractors should make sure paper and printouts are not left where unauthorised people could see them, like on a printer or desk.
    • Data printouts should be shredded and disposed of securely when no longer required.
    • By law all client medical notes & records must be kept on file for at least 8 years, financial records for 6 years. At the end of each government financial year (1st April to 31st March), these are archived and locked away for secure storage.
    • 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 that are changed regularly and never shared between employees.
    • The CRM uses a secure password-less system with one-time links, so the above only applies to desktop & mobile computers/devices where data is viewed & saved.
    • If data is stored on removable media (like a CD or DVD, USB memory stick or memory card), 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. Personal & sensitive data should never be stored on third party cloud servers.
    • Servers containing personal data should be sited in a secure location, away from general office space.
    • 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 mobile devices like tablets or smart phones.
    • Mobile laptops that have data stored directly to them, should have a secure password for them and always be locked whenever left unattended. If leaving them for any length of time when not at work, they should be locked away in a secure place.
    • All servers and computers containing data should be protected by approved security software and a firewall.

    Data Use

    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:

    • 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. Card details & bank account information should never be sent by email, and any other personal data should have minimal contact with email, and only when necessary if it cannot be sent in any other way, as this form of communication is not secure.
    • Data must be encrypted before being transferred electronically.
    • Personal & sensitive data is stored on servers in the UK and 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.

    Data Accuracy

    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.

    • 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.
    • Anamchara Retreats Ltd / Amchara Ltd will make it easy for data subjects to update the information Anamchara Retreats Ltd / Amchara Ltd holds about them. For instance, over the phone, by email or via the company website.
    • 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 database.

    Subject Access Requests

    All individuals who are the subject of personal data held by Anamchara Retreats Ltd / Amchara Ltd 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 [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.

    Information Removal Requests

    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.

    Disclosing Data for Other Reasons

    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, which 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.

    Providing Information

    Anamchara Retreats Ltd / Amchara Ltd 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.

    The company privacy statement is available on request, and is also available on the company’s website @ www.amchara.com/privacy

    Please note:

    Although this Data Protection Policy is directed towards the staff at Anamchara Retreats Ltd / Amchara Ltd, it is also visible to the public via our website @ www.amchara.com/internal-data-protection-policy