Privacy policy.
Introduction
The Good Skin Company needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees and other people the organisation 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 company’s data protection standards, and to comply with the law.
Why this policy exists
This data protection policy ensures that The Good Skin Company:
Complies with data protection law and follows good practice
Protects the rights of employees, 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 UK Data Protection Act 1998 and the General Data Protection Regulation (GDPR) May 2018 describes how organisations, including the The Good Skin Company 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, not disclosed unlawfully, and deleted appropriately.
The Data Protection Laws are underpinned by eight important principles. These say that personal data must:
Be processed fairly and lawfully
Be obtained only for specific, lawful purposes
Be adequate, relevant and not excessive
Be accurate and kept up to date
Not be held for longer than is necessary
Be processed in accordance with the rights of data subjects
Be protected in appropriate ways
Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
The GDPR adds weight to the law by enforcing that data must:
Be processed fairly, lawfully and transparent
Be processed for limited purposes and not in any manner incompatible for those purposes
Be accurate and where necessary kept up to date
Be kept secure and processed in line with the individuals’ rights
Policy Scope
This policy applies to:
All locations of The Good Skin Company
All employees or The Good Skin Company
All contractors, suppliers and other people working on behalf of The Good Skin Company
It applies to all data that the company holds relating to identifiable individuals. This can include:
A mobile phone number
First and last name
Postal addresses
Email addresses
Telephone numbers
Content of personal communications sent and received via The Good Skin Company
The following information is to be classed as personal sensitive data:
Prescriptions – both original and scanned copies
All medical assessment forms and Continuation Forms
Photography
Data Protection Risks
This policy helps to protect The Good Skin Company from data security risks, including:
Breaches of confidentiality. Example – information being shared inappropriately
Failing to offer choice. Example – all individuals should be free to choose how the company uses data relating to them subject to regulatory requirements
Reputational damage. Example – the company could suffer if hackers successfully gained access to sensitive data
Responsibilities
Everyone who works for or with The Good Skin Company has responsibility for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that it is handled and processed in line with this policy and the data protection principles.
However, these people have key areas of responsibility:
The Director(s) are ultimately responsible for:
ensuring that The Good Skin Company meets its legal obligations
The Data Protection Officer is responsible for:
Keeping the Directors and Team updated about data protection responsibilities, risks and issues
Reviewing all data protection procedures and related policies, in line with an agreed schedule
Arranging data protection training and advice for the people covered by this policy
Handling data protection questions from staff and anyone else covered by this policy
Dealing with requests from individuals to obtain the data held about them (also called ‘subject access requests’)
Checking and approving any contracts or agreements with third parties that may handle the companies sensitive data
Being a contact for any enquiries made from the Guernsey Data Commissioners office
The Team is responsible for:
Ensuring all systems, services and equipment used for storing data meet acceptable security standards
Ensuring regular checks and scans are conducted to confirm 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
The Director is responsible for:
Approving any data protection statements attached to email and letter communications
Addressing any data protection queries from the media
Where necessary, working with other staff to ensure marketing initiatives abide by data protection and GDPR principle
Employee Guidelines
The only people able to access data covered by this policy should be those who need it for their work
Data should not be shared informally
The Good Skin Company will provide training to all employees to help them understand their responsibilities when handling data
Employees should keep all data secure, by taking sensible precautions and following the guidelines below
In particular, strong passwords must be used and they should never be shared
Personal data should not be disclosed to unauthorised people
Data, whether on disk or paper should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and securely disposed of
Employees should request help from their line manager or the Data Protection Officer if they are unsure about any aspect of data protection
Contractor Guidelines
The only people able to access data covered by this policy should be those who need it for their work.
The data should not be shared informally
The Good Skin Company will provide training to all employees to help them understand their responsibilities when handling data
Employees should keep all data secure, by taking sensible precautions and following the guidelines below
In particular, strong passwords must be used and they should never be shared. This is written into your contractual obligations to The Good Skin Company Ltd
Personal data should not be disclosed to unauthorised people. This is written into your contractual obligations to The Good Skin Company Ltd
Data, whether on disk or paper should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and securely disposed of
Employees should request help from their line manager or the Data Protection Officer if they are unsure about any aspect of data protection
Data Storage
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to their line manager, any member of the Exec Team, or the Data Protection Officer.
When data is stored on paper, it 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 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 lying where unauthorised people can see it. Example – printed documents left on a printer or a re-cycling bin
Data printouts should be shredded and disposed of securely when no longer required
When data is stored electronically it must be protected from unauthorised access, and malicious hacking attempts:
Data should be protected by strong passwords that are changed regularly and never shared with fellow employees
If data is stored on removable media (CD,DVD,USB stick etc) these should be kept locked away securely when not being used
Data should only be stored on designated drives and servers and should only be uploaded to approved cloud computing services
Servers containing personal or sensitive data should be sited in a secure location with safety detection
Data should be backed up frequently. Those backups should be tested regularly for integrity.
Personal or sensitive data should never be saved directly to laptops or other mobile devices like tablets or smart phones
All servers and computers containing data should be protected by approved security software and firewalls
For more information regarding the safe storage and destruction of data, refer to the The Good Skin Company Data Storage, Retention and Destruction Policy.
Data use
Personal or sensitive data is of no value to The Good Skin Company unless it is relevant to the business. However when it is used, it is at the greatest risk of loss, corruption or theft:
When working with personal data, employees should ensure the screens of their computers are always locked when left unattended
Personal or sensitive 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 sent electronically. The Date Protection Officer can explain how to send data to authorised external contacts
Personal data should never be transferred outside of the European Economic Area unless that country has adequate data protection
Employees should never save copies of personal data to their own computers, IT devices, or mobile telephones, it should be normal practice to access and update the central copy of any dat
Data Accuracy
The law requires The Good Skin Company to take reasonable steps to ensure data is kept accurate and up to date. It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and as up to date as possible.
Data will be held in as few places as necessary
Unnecessary additional data sets should not be created
Every opportunity should be taken to ensure data is updated by confirming customers details when they call
The Good Skin Company will make it easy for data subjects to update the data held about them via email or the e-pharmacy website
Data should be updated as inaccuracies are discovered in a timely fashion
Subject Access Requests
All individuals who are the subject of personal data held by The Good Skin Company are entitled to:
Ask what information the company 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 company is meeting its data protection obligations
If an individual contacts the company requesting this information, this is called a ‘subject access request’.
Subject access requests from individuals should be made by email to the Data Protection Officer, in most circumstances individuals will not be charged for this service. The company will verify the identity of the individual and then provide this information within 1 month.
The data will be transferred to the individual using an encrypted USB stick
Disclosing data for other reasons
In certain circumstances, the Data Protection Law allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances The Good Skin Company will disclose the requested data. However, the Data Protection Officer will ensure the request is legitimate, seeking assistance from the Board and the company’s legal advisors where necessary.
Providing Information
The Good Skin Company 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
To these ends, the company has a Privacy Statement, setting out how data relating to individuals is used by the company.
The Privacy Statement is available on request and a version is also available on the company website thegoodskincompany.com