Data Protection Policy
Data Protection Officer: Naomi Nightingale, you can contact me via the contact form on this website
Last updated: 21/05/18
1. Data protection principles
I am committed to processing data in accordance with its responsibilities under the GDPR. Privacy is of course also vitally important in my roles as a counsellor and mediator and so I take the topic extremely seriously.
Article 5 of the GDPR requires that personal data shall be:
- a. processed lawfully, fairly and in a transparent manner in relation to individuals.
- b. 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.
- c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- d. 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 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.
- 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.
2. General provisions
- a. This policy applies to all personal data processed by us.
- b. The Data Protection Officer takes responsibility for my ongoing compliance with this policy.
- c. This policy shall is reviewed at least annually.
- d. I am registered with the Information Commissioner’s Office as a Data controller. Reference: Z267172X
3. Lawful, fair and transparent processing
- a. To ensure its processing of data is lawful, fair and transparent, I maintain a Data Mapping document which tracks the systems I use to hold data and access.
- b. This document is reviewed at least annually.
- c. Individuals have the right to access their personal data and any such requests made shall be dealt with in a timely manner. Please simply contact the Data Protection Officer.
4. Lawful purposes
- a. All data processed by is must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests
- b. I note the appropriate lawful basis in my Data Mapping document.
- c. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available.
5. Data minimisation
- a. I work to ensure that I only gather the personal information needed. For example I do not mandate address info on my enquiry form.
- a. I take reasonable steps to ensure personal data is accurate.
- b. 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
- a. To ensure that personal data is kept for no longer than necessary, I have put in place an archiving policy for each area in which personal data is processed. I review this annually. This is detailed in my Data Mapping document.
- b. The archiving policy shows what data should/must be retained, for how long, and why.
- a. I ensure that personal data is stored securely using modern software that is kept-up-to-date.
- b. Access to personal data is limited to personnel who need access and appropriate security is in place to avoid unauthorised sharing of information.
- c. When personal data is deleted this should be done safely such that the data is irrecoverable. I will tend to over-write the existing data rather then just plain deleting it.
- d. Appropriate back-up and disaster recovery solutions are in place.
- e. Data communicated via my website is fully secured with SSL.
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, I shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO.