Rebalancing Life (Sadhna Chaman) Data Protection Policy
Scope of the Policy
Why this policy exists
This data protection policy ensures that Rebalancing Life
- Complies with data protection law and continues to follow good practice
- Protects the rights of patients
- Is open about how information is stored and processed
- Protects itself from the risks of a data breach
Article 5 of the GDPR identifies the following eight key requirements of data protection:
- Personal data shall be processed lawfully, fairly, and in a transparent manner.
- Personal data can only be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible for those purposes.
- Personal data must be adequate, relevant, and limited to what is necessary in relation to the purposes for which it is collected.
- Personal data held should be accurate and current. Inaccurate data should be erased or corrected.
- Data which allows for the identification of an individual, should be kept for no longer than is necessary.
- The processing of personal data must safeguard the rights and freedom of individuals
- Personal data must be processed in a manner which ensures appropriate security of the data. This includes protection against unauthorised or unlawful processing of the data, and accidental loss, destruction or damage of the data. This means having appropriate technological or managerial systems in place.
- Personal data cannot be transferred outside of the EU unless the country to which it is being transferred provides an adequate level of protection for the rights and freedoms of individuals in relation to the processing of personal data.
Certain of these principles are expanded upon in the sections that follow
Lawful, fair and transparent data processing
Rebalancing Life requests personal information from patients and potential patients for the purpose of consulting with them and providing them with advice and guidance on the various therapies provided. The forms use to request personal information may contain a privacy statement informing patients and potential patients why the information is being requested and what the information will be used for.
Patients should be asked to provide consent for their data to be held and a record of this consent along with patient information will be securely held and a record of this consent along with patient information will be securely held. Patients will be informed that they can, at any time remove their consent and will be informed as to what to do should they wish to do so.
Processed for Specified, Explicit and Legitimate Purposes
Patients will be informed how their information will be used and Rebalancing Life will seek to ensure that patient’s information is not used inappropriately. Appropriate use of information provided by patients includes:
- Communicating with patients in order to make, change or cancel consultations
- Assessing the conditions and issues reported by patients and devising and prescribing relevant remedies and therapies
- Rebalancing Life will ensure that patients’ information is managed in such a way as to not infringe an individual’s rights which include:
- The right to be informed
- The right of access
- The right to rectification
- The right to restrict processing
- The right to data portability
- The right to object
Adequate, Relevant and Limited Data Processing
Rebalancing Life’s patients will only be asked to provide information that is relevant to support their treatment. This includes:
- Date of birth
- Postal address
- Email address
- Telephone number
- Medical history
Where additional information may be required, this will be obtained with the specific consent of the patient who will be informed as to why this information is required and the purpose for which it will be informed as to why this information is used.
Rebalancing Life will never share any patient information with a third-party. There may be occasional instances where a patient’s information may need to be shared with a third party due to an accident or incident involving statutory authorities, in which case consent does not have to be sought from the individual.Where it is in the best interests of the patient or of Rebalancing Life, in these instances where Rebalancing Life has a substantiated concern then consent does not have to be sought from the individual.
Accuracy of Data And Keeping Data up to Date
Rebalancing Life has a responsibility to ensure that patients’ information is kept up to date. Patients will be required to let Rebalancing Life know if any of their personal information changes.
Accountability and Governance
Rebalancing Life is responsible for ensuring that its service remains compliant with data protection requirements and can provide evidence that it has. For this purpose, those from whom data is required will be asked to provide written consent. The evidence of this consent will then be securely held as evidence of compliance.
Rebalancing Life has a responsibility to ensure that data is both securely held and processed. This includes:
- Using strong passwords for information held within computer systems
- Restricting access to computer and paper based files
- Using password protection on laptops and PCs that contain or access personal information
- Using password protection or secure cloud systems
- Providing adequate virus-protection and firewall software to secure computer-based information
Subject Access Request
Rebalancing Life’s patients are entitled to request access to the information that is held on them. The request needs to be received in the form of a written request to Rebalancing Life.
On receipt of the request, the request will be formally acknowledged and dealt with within 14 days unless there are exceptional circumstances as to why the request cannot be granted. Rebalancing Life will provide a written response detailing all information held on the individual. A record shall be kept of the date of the request and the date of the response.
Data Breach Notification
Should a data breach occur, action shall be taken to minimise the harm. Rebalancing Life will inform any patients where it believes their personal information has been compromised. Where necessary, the Information Commissioner’s Office will be notified.
If a patient contacts Rebalancing Life to say that they feel that there has been a breach by Rebalancing Life, Sadhna Chaman will ask the patient to provide an outline of their concerns in writing by email or a letter. The concern will then be investigated fully and a response made to the patient. Breach matters will be subject to a full investigation, records will be kept and all those involved will be notified of the outcome.
Policy review date: Every 2 years, next review planned July 2022