Imago Health and Safety Consultant’s GDPR policy
1. Statement of policy
Imago Health and Safety Consultants is fully committed to compliance with the requirements of the General Data Protection Regulation (GDPR), Data Protection Act 2018 and any successor legislation (together, the ‘data protection legislation’). Imago Health and Safety Consultants is committed to a policy of protecting the rights and freedoms of individuals with respect to the processing of their personal data and special category personal data.
Imago Health and Safety Consultants will therefore follow procedures which aim to ensure that all employees and volunteers, and others who have access to any personal data held by or on behalf of the Imago Health and Safety Consultants, are fully aware of and responsible for the handling of personal data in line with the data protection legislation.
In order to operate efficiently, Imago Health and Safety Consultants has to collect and use information about people with whom it works. These may include current, past and prospective clients; current, past and prospective employees; and our suppliers.
Data protection legislation and in particular Article 5 (1) of the GDPR requires that personal data shall be used in accordance with the following principles:
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; and
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.”
Article 5 (2) of the GDPR requires that:
“the controller shall be responsible for, and be able to demonstrate, compliance with the principles.”
Lawful basis for processing personal data under the data protection legislation
Imago Health and Safety Consultants primarily uses legitimate interest to process client personal data.
Imago Health and Safety Consultants also process personal data under the following lawful bases:
Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
Lawful basis for processing special category personal data
Imago Health and Safety Consultants process special category personal data under the following lawful bases:
Explicit consent: the data subject has given explicit consent to the processing of those personal data for one or more specified purposes.
2. Handling of personal data and special category personal data
Imago Health and Safety Consultants will, through appropriate management and the use of appropriate controls adhere to the following in regards to our use of personal data and special category personal data;
- Provide up to data privacy notices to data subjects
- Collect and process appropriate information and only to the extent that it is needed to fulfil operational needs or to comply with legal requirements
- Ensure the quality and accuracy of information when collected or received and during its use
- Apply checks to determine the length of time information is retained
- Take appropriate technical and organisational security measures based on risks to data subjects.
- Not transfer outside the EEA without suitable safeguards
- Ensure that any information incidents are reported where appropriate to the data subject and the Information Commissioner's Office
- Mitigate risks to the data subjects in the event of an information incident using an appropriate data breach policy
- Ensure that the rights of our data subjects can be properly exercised.
These rights include:
- The right to be informed
- The right of access
- The right to rectification
- The right to erase
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
In addition, we will ensure that:
- There is someone with specific responsibility for data protection in the organisation. The post responsible for data protection is Data Protection Manager.
- Organisational information and in particular privacy risks are risk assessed, documented and controlled.
- Everyone managing and handling personal data and special category personal data understands that they are responsible for following good Information Governance / Assurance practice and for complying with the data protection legislation.
- Everyone managing and handling personal data and special category personal data is appropriately trained and supervised to do so.
- Queries about processing personal data and special category personal data are promptly and courteously dealt with within the requirements of the data protection legislation.
- Data sharing and processing is carried out under an appropriate written agreement, setting out the scope and limits of the sharing. Any disclosure of personal data will be in compliance with approved procedures.
All employees and volunteers are to be made fully aware of this policy and their duties and responsibilities under it. All employees and volunteers will take steps to ensure that personal data is kept secure at all times against unauthorised or unlawful loss or disclosure.
This Policy will be reviewed annually and its implementation monitored by the Management Team.
Date:
25/11/2022