The Wellbeing People
Website Privacy Statement
The Purpose of this privacy statement is to explain how The Wellbeing People processes personal data to fulfil its data protection responsibilities. This statement will be supplemented by ‘specific to client’ privacy notices when needed. The scope of this statement covers all related activities by the staff of The Wellbeing People referred to as TWP for the remainder of this document.
The Role of TWP in data protection terms is that of a data controller where it determines the purpose and use of personal data collected. Once received it becomes the responsibility of the TWP privacy manager (PM) to ensure that it is processed in accordance with the latest UK data protection legislation. The PM can be contacted by email using firstname.lastname@example.org. TWP is registered with the Information Commissioner’s Office (ICO).
The personal data processed by TWP will be basic contact information for the purposes of responding to general enquiries, business development, preparing contracts and setting up invoices. Due to the nature of the services being offered, it will also be necessary to collect and process health related data. If TWP is not given all of the requested information, it may result in an incomplete service being provided.
TWP’s duty of confidentiality means that TWP staff will treat clients’ personal data with due respect and in confidence. It is only disclosed to those that need to know it. TWP uses reasonable organisational and technical measures to ensure personal data is kept secure. TWP also expects the same duty of confidentiality of all third parties with whom it shares personal data, including sub-contractors. Sharing is kept to a minimum and reviewed regularly.
TWP processes personal data against a lawful basis as described below:
· To respond to your general enquiries, we will use our legitimate interests
· To comply with our legal obligations
· To fulfil our contractual obligations including their prior preparation. This includes the processing of special category data when it is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of employees, and assessment of the wellbeing of children and the management of health or social care of individuals.
· To act in the vital interests of clients if confronted with an emergency situation
· When processing a pre-defined purpose for which your consent has been sought and recorded prior to that processing commencing,
In all cases the processing of personal data by TWP shall be:
· Processed lawfully, fairly and transparently
· Collected for specified, explicit and legitimate purposes
· Adequate, relevant and limited to what is necessary (and no more)
· Accurate and, when necessary, updated
· Kept for no longer than is necessary
· Processed in a manner that ensures appropriate security.
TWP will share personal data, but only when absolutely necessary, with some or all of the following third parties:
· The Inland Revenue (HMRC)
· Solicitors appointed by TWP
· Emergency services
· Other health professionals but only with prior consent
· Accountants appointed by TWP and only for accounting purposes
· Unspecified recipients but only when compelled to do so for legal reasons
TWP will process your personal data in the UK and backed up using a cloud service provider. Email is processed using a reputable web-based provider and mobile phone contacts are stored on both office IT equipment and mobile phones.
TWP follows a retention schedule to determine the length of time it holds different types of personal data. The retention schedule is shown below:
· Routine correspondence for casual enquiries in hard copy or in emails will be stored for one year
· Contract related data will be retained throughout the life of the contract plus another 8 years following the termination of the contract
· Completed feedback forms from workshops will be retained for 2 months after the workshop was conducted and then destroyed
· Contact data is stored indefinitely unless a valid request to erasure is received from the interested data subject
· Financial records and invoices, which may include personal data, will be retained for 6 years after the end of the current tax year of processing
· By exception, documentation that includes personal data may be retained by TWP beyond the schedule, but only for a specific purpose and only when TWP believes there is a legitimate interest or a legal obligation to do so
At the end of the retention schedule TWP will either return, destroy or delete your personal data and any associated emails or relevant documentation. If it is technically impractical to delete electronic copies of personal data, it will put it beyond operational use. It should be noted that TWP allows up to 3 months after the retention schedule to complete the action.
The TWP website links to appropriate business websites of interest. If these are used, you should be aware that the TWP has no responsibility for the control, content or handling of your personal data by these other websites.
The General Data Protection Regulation defines the rights that you have (although these do not apply in all situations), For convenience, these rights are shown below:
· Right to be informed as to how your personal data is being processed by TWP – this is done through this statement or specific to customer privacy notices
· Right to access your personal data held by TWP which is done by making a ‘Data Subject Access Request’ (DSAR) to the privacy manager
· Right to rectification of your personal data if you believe TWP has collected it incorrectly or it needs to be updated
· Right to erasure of your personal data for which TWP no longer has a legitimate purpose to process
· Right to restrict processing under certain circumstances, during which time your personal data but will be out of operational use until the related matter is resolved;
· Right to data portability of your personal data in a machine-readable version, as you have provided but only applicable to data provided with your consent or under contract
· Right to object to TWP processing your personal data for which it does not have a legal or contractual obligation
· Rights related to automated decision making and profiling (however TWP does not use these techniques in its decision making)
Further details on data subjects’ rights can be found on the Information Commissioner’s Office (ICO) website: https://ico.org.uk
Raising concerns, exercising rights or making queries about TWP’s processing of personal data can be done by contacting the privacy manager. Please be aware that we will need to determine your identity before responding fully, therefore, you may be asked for proof of ID or other material that, in context, will enable us to confirm your identity. Alternatively, you may wish to contact the ICO directly, using the details provided above.