Golden Stars Play Therapy needs to gather and use certain information about individuals.
These can include schools, parents/carers, agencies, other professions and other people the Service 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 Service’s data protection standards — and to comply with the law.
DATA PROTECTION POLICY OF GOLDEN STARS PLAY THERAPY
Why this policy exists
This data protection policy ensures Golden Stars Play Therapy Service:
* Complies with data protection law and follow good practice
* Protects the rights of 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 GDPR (General Data Protection Regulation), effective in the UK from 25 May 2018) describes how organisations/services 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 important principles. These say that personal data must be:
a) Be processed lawfully, fairly and in a transparent manner in relation to the data subject
b) Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing or 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) Be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
d) Be 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; subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject
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.
People, risks and responsibilities
This policy applies to:
Emma Giles at Golden Stars Play Therapy.
It applies to all data that the Service holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:
* Names of individuals
* Postal addresses
* Email addresses
* Telephone numbers
* ICE (in case of emergency) contact details
* Plus any other information relating to individuals
Data protection risks
This policy helps to protect service users from some very real 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 Service uses data relating to them
* Reputational damage. For instance, service users could suffer if hackers successfully gained access to sensitive data
As a data controller and processor Golden Stars Play Therapy has responsibility for ensuring that data is collected, stored, processed and handled appropriately in line with this policy and data protection principles.
Emma Giles is registered with the ICO (Information Commissioner’s Office), reference: ZA256806
Golden Stars Play Therapy has the responsibility of:
* Keeping updated about data protection responsibilities, risks and issues
* Reviewing all data protection procedures and related policies annually
* Handling data protection questions from service users covered by this policy
* Dealing with requests from individuals to see the data Emma Giles holds about them
* Checking and approving any contracts or agreements with third parties that may handle Service’s sensitive data
* Ensuring all systems, services and equipment used for storing data meet acceptable security standards
* Performing regular checks and scans to ensure security hardware and software is functioning properly
* Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services
* Only Golden Stars Play Therapy are able to access data covered by this policy when needed for work
* Data will not be shared informally. All data will be treated as confidential information
* Golden Stars Play Therapy will keep all data secure, by taking sensible precautions and following the guidelines below
* In particular, strong passwords will be used and never shared
* Personal data will not be disclosed to unauthorised people, either within the Service or externally
* Data will 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
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to Emma Giles, the data controller.
Data 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 should make sure paper and printouts are not left where unauthorised people could see them, like on a printer
* Data printouts should be shredded and disposed of securely when no longer required
Data 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
* If data is stored on removable media (like a memory stick), these should be kept locked away securely when not being used
* 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 phones
* All computers containing data should be protected by approved security software and a firewall
Personal data is of no value to Golden Stars Play Therapy unless the Service 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, Golden Stars Play Therapy should ensure the screens of computers are always locked when left unattended
* Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure
* Data must be encrypted before being transferred electronically
* A central copy of any data should be used to access and update when needed
The law requires Golden Stars Play Therapy 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 Golden Stars Play Therapy should put into ensuring its accuracy.
* Data will be held in as few places as necessary. There will not be any unnecessary additional data sets
* Golden Stars Play Therapy will take every opportunity to ensure data is updated. For instance, by confirming details during a call
* Golden Stars Play Therapy will make it easy for data subjects to update the information the Service holds about them
* Data should be updated as inaccuracies are discovered
Subject Access Requests
All individuals who are the subject of personal data held by Golden Stars Play Therapy are entitled to:
* Ask what information the Service 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 Service is meeting its data protection obligations
If an individual contacts the Service 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, Emma Giles at firstname.lastname@example.org
The data controller can supply a standard request form, although individuals do not have to use this. The data controller will aim to provide the relevant data within 30 days.
The data controller will always verify the identity of anyone making a subject access request before handing over any information
Disclosing data for other reasons
In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Golden Stars Play Therapy will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from legal advisers where necessary.
Golden Stars Play Therapy 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