DATA PROTECTION POLICY 

This policy applies to the work of homeopath Stephanie Thullen Homeopathy. The policy sets out the requirements that Stephanie Thullen Homeopathy has in order to gather personal information for professional purposes. The policy details how personal information will be gathered, stored and managed in line with data protection principles and the General Data Protection Regulation. The policy is reviewed on an ongoing basis to ensure that the Stephanie Thullen Homeopathy is compliant. This policy should be read in tandem with the Stephanie Thullen Homeopathy’s Privacy Policy. 
Why this policy exists 

This data protection policy ensures that Stephanie Thullen Homeopathy:

• complies with data protection law and follows good practice
• protects the rights of patients
• is open about how she stores and processes patients’ data
• protects herself from the risks of a data breach.

DEFINITIONS

Company means Stephanie Thullen Homeopathy
GDPR means the General Data Protection Regulation.
Responsible Person: Appointed Data Protection Trustee Representative Stephanie Thullen
Register of Systems means a register of all systems or contexts in which personal data is processed by Stephanie Thullen Homeopathy

1. DATA PROTECTION PRINCIPLES
Stephanie Thullen Homeopathy is committed to processing data in accordance with its responsibilities under the GDPR. 

Article 5 of the GDPR requires that personal data shall be:

1. processed lawfully, fairly and in a transparent manner in relation to individuals;
2. 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;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. 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;
5. 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 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.

2. GENERAL PROVISIONS

1. This policy applies to all personal data processed by Stephanie Thullen Homeopathy.
2. The Responsible Person shall take responsibility for Stephanie Thullen Homeopathy’s ongoing compliance with this policy.
3. This policy shall be reviewed at least annually.
4. Stephanie Thullen Homeopathy is registered with the Information Commissioner’s Office as an organisation that processes personal data.

3. LAWFUL, FAIR AND TRANSPARENT PROCESSING

1. To ensure its processing of data is lawful, fair and transparent, Stephanie Thullen Homeopathy shall maintain a Register of Systems.
2. The Register of Systems shall be reviewed at least annually.
3. Individuals have the right to access their personal data and any such requests made to Stephanie Thullen Homeopathy shall be dealt with in a timely manner.

4. LAWFUL PURPOSES

1. All data processed by Stephanie Thullen Homeopathy must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
2. Stephanie Thullen Homeopathy shall note the appropriate lawful basis in the Register of Systems.
3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in Stephanie Thullen Homeopathy’s systems. 

5. DATA MINIMISATION

1. Stephanie Thullen Homeopathy shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

6. ACCURACY

1. Stephanie Thullen Homeopathy shall take reasonable steps to ensure personal data is accurate.
2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. ARCHIVING / REMOVAL

1. To ensure that personal data is kept for no longer than necessary, Stephanie Thullen Homeopathy shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
2. The archiving policy shall consider what data should/must be retained, for how long, and why.
3. As a licensed and registered homeopath, I am required to retain records for 7 years.

8. SECURITY

1. Stephanie Thullen Homeopathy shall ensure that personal data is stored securely using modern software that is kept up-to-date. 
2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
3. When personal data is deleted this should be done safely such that the data is irrecoverable.
4. Appropriate back-up and disaster recovery solutions shall be in place.

9. PRIVACY POLICY
Stephanie Thullen Homeopathy takes your privacy seriously and will only use your personal information to administer any treatment you have requested or to send you relevant information via emails and newsletters.  We will not share your data with any third parties*
* Analytics information:
We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.

10. BREACH
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Stephanie Thullen Homeopathy shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website). 

END OF POLICY

Policy review date: 1 April 2022