DATA PROTECTION POLICY
Scope of the policy
This policy applies to the work of homeopath Caroline Harper (hereafter referred to as ‘CH’). The policy sets out the requirements that CH 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
Why this policy exists
This data protection policy ensures that CH:
• 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.
Data protection principles
The General Data Protection Regulation identifies 8 data protection principles.
Principle 1 - Personal data shall be processed lawfully, fairly and in a transparent manner
Principle 2 - Personal data can only be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
Principle 3 - The collection of personal data must be adequate, relevant and limited to what is necessary compared to the purpose(s) data is collected for.
Principle 4 – Personal data held should be accurate and, where necessary, kept up to date. Every
reasonable step must be taken to ensure that personal data that are inaccurate are erased or rectified without delay.
Principle 5 – Personal data which is kept in a form which permits identification of individuals shall not be kept for longer than is necessary.
Principle 6 - Personal data must be processed in accordance with the individuals’ rights.
Principle 7 - Personal data must 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.
Principle 8 - Personal data cannot be transferred to a country or territory outside the European Union unless that country or territory ensures 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
CH requests personal information from patients and potential patients for the purpose of consulting with them and providing them with advice and guidance on homeopathic treatments. The forms used to request personal information will contain a privacy statement informing patients and
potential patients why the information is being requested and what the information will be used for. Patients will 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. 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 CH will seek to ensure that
patients’ information is not used inappropriately. Appropriate use of information provided by
• 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.
CH will ensure that patients’ information is managed in such a way as to not infringe an individual patient’s rights which include:
• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object.
Adequate, Relevant and Limited Data Processing
CH’s patients will only be asked to provide information that is relevant to support consultations and prescription. 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 used.
There may be occasional instances where a patient’s information needs to be shared with a third party due to an accident or incident involving statutory authorities. Where it is in the best interests of the patient or of CH, in these instances where CH has a substantiated concern, then consent does not have to be sought from the patient.
Accuracy of Data and Keeping Data up to Date
CH has a responsibility to ensure that patients’ information is kept up to date. Patients will be
required to let CH know if any of their personal information changes.
Accountability and Governance
CH is responsible for ensuring that her practice 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.
CH 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
Subject Access Request
CH’s patients are entitled to request access to the information that is held by the CH. The request needs to be received in the form of a written request to CH.
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. CH will provide a written response detailing all information held on the member. A record shall be kept of the date of the request and the date of the response.
Data Breach Notification
Were a data breach to occur, action shall be taken to minimise the harm. CH will inform any
patients where she believes their personal information has been compromised. Where necessary, the Information Commissioner’s Office would be notified.
If a patient contacts CH to say that they feel that there has been a breach by CH, she will ask the patient to provide an outline of their concerns. If the initial contact is by telephone, CH will ask the patient to follow this up with an email or a letter detailing their concern. 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 notified of the outcome.
Policy review date: 25th May 2020
Caroline Harper BSc(Hons) LCHE BA(Hons) CMA
What personal information do I collect?
In order to treat you, I will ask you to provide certain information. This includes:
• Date of birth
• Home address
• Email address
• Telephone number
• Medical history
To this, over time, I will add details of the conditions for which you have consulted me and the remedies and other therapies that I have prescribed or recommended.
How do I collect this personal information?
All the information collected is obtained directly from you. This is usually at the point of your initial consultation. At the point at which you provide your personal information, I will also request that you provide consent for me to store and use your data. Your consent is required in order to ensure my
compliance with data protection legislation. Subsequently, I will add to this initial information with
details of the consultations you hold with me.
How do use this personal information?
I use your personal information to analyse the conditions for which you have consulted me and to
prescribe remedies and other therapies.
I will communicate with you by email, other digital methods (my newsletter), by telephone and by post.
With whom do I share your personal information?
I do not share your personal information.
How long do I keep your personal information?
I need to keep your information for as long as you continue to consult me. Since patients often return for more consultations after a period of absence, I will keep your information for 7 years after your last consultation. At that point, your file will be securely destroyed and any digital information will be erased from my computer systems.
How your information can be updated or corrected
To ensure that I have accurate and up-to-date information, you need to inform me of any changes you believe I should make to the personal information I hold. You can do this by contacting me by any of the methods previously described.
Under data protection legislation, you have the right to inspect the personal information I hold about you. You can make a request to do so by contacting me and I will endeavour to respond within 14 working days.
How do I store your personal information?
My patient files are paper-based and are held securely within my consulting room. I take steps to protect your personal information against loss or theft, as well as unauthorised access, disclosure, copying, use, or modification.
Your email address, if you have one, is held securely on the servers of my email providers, currently Fasthosts and Google mail.
Changes to this policy
This policy may change from time to time. If I make any material changes, I will make you aware of them.
Please contact me if you have any queries about this policy, need it in an alternative format, or have any complaints about my privacy practices:
195 Lauderdale Mansions
London W9 1LZ
Tel: 07930 987858
Policy review date: 25th May 2020