Data Protection

Policy towards data protection
It is our policy to treat customers, staff and all other stakeholders within the business (data subjects) fairly and lawfully when processing, storing and sharing their personal data.

We are currently not required to register with the Information Commissioners Office (ICO).

Our Centre will treat all personal information as private and confidential, even when the data subject’s records have lapsed or are cancelled and we will not release information to anyone else except where:

• The data subject gives us explicit, unambiguous consent
• We have to by law
• Processing by another party, such as a pet insurer or veterinary practice, is necessary for the performance of a contract to which the data subject is party or in order to take the necessary steps prior to the data subject entering into a contract

Data we hold will, at all times, be processed and stored securely and within the requirements of the General Data Protection Regulations (GDPR).

Governance
Privacy by design is an implicit requirement of data protection and we have a general obligation to implement technical and organisational measures to show that we have considered and integrated data protection into our processing activities.

Our firm understands the importance of having robust governance, systems and controls in place to protect the rights of data subjects and to ensure our on-going compliance with the requirements of the GDPR.

Anne Johnson has primary responsibility for GDPR ensuring that compliance with the regulations is central to the culture within our business and that all staff are discharging their duties appropriately with regard to personal data. Also, that our Privacy Notice remains accurate and up to date and that we maintain an archive of all Privacy Notices issued.

In addition to regular, proportionate checks and audits of our internal procedures, it is our practice to undertake proportionate enquiries of our third-party data processors to ensure they remain compliant with GDPR on an on-going basis.

Legal Basis
We will ensure that at all times, we are legally able to process, store and share personal identifiable information. Where necessary, for example for marketing purposes or when special category data is involved, we will obtain explicit consent from the data subject.

Personal Identifiable Information is:
• Any information relating to a living person that can be used to directly or indirectly identify that person
• Full name, email address, date of birth, IP address / website cookies
• Purchases, downloads, subscriptions and services used
• Questions and responses, promotions used, survey responses
• Financial history, banking/credit, payment transactions and donations
• Healthcare and education services used
• CCTV recordings, gender identity, location data, credit card data
• Judgements/sanctions, government services
• Capable of identifying an individual either on its own or when combined with other information
• Internal account numbers, PINs and passwords, IMEIs, National Insurance number
• Driving licence number, passport number

Special Category / High Risk Data is:
• Race/ethnic origin, political opinions, religious beliefs and union membership
• Biometric, genetic, health/medical data
• Sexual orientation, sex life
• Criminal offenses, criminal convictions

Consent
Consent must be freely given, unambiguous and on an opt-in, not opt-out basis. Consent must not be a condition of provision of service.

We will ensure that consent for the use of personal data is obtained specifically for each of purpose and separately from consent to any other terms or conditions.

All data subjects will be provided with a copy of, or access to, our Privacy Notice. We will retain an archive of version-controlled Privacy Notices.

Sharing Data
We acknowledge that it will be necessary to share personal identifiable information, including special category data, with third parties (data processors) in order to facilitate and assist with the on-going performance of a contract with our data subjects. For example, pet insurers, veterinary practices, payroll services etc.

We will take proportionate steps to ensure that all third parties receiving data from us are compliant with GDPR requirements. We recognise that a failure of one of our data processors to comply with the GDPR directly affects our ability to comply.

Data will not be transferred/stored outside the United Kingdom.

Retention of Data
We recognise that the GDPR require us to hold data for no longer than is absolutely necessary. Data will therefore be stored in line with our data retention policy.

Any request from a data subject to have their data erased must be processed taking into account our legal requirements on data retention, as specified by the Information Commissioner, the Companies Act or other legislation, whichever requirement is the longer.

We will take necessary, proportionate steps to ensure that all data we hold is at all times kept secure, both manual and electronically held data, while ‘at rest’ on our systems, in transit to and stored by any third party. Such measures may include but not be limited to:
• Keeping manual files in locked cabinets when not in use
• Operating a clear desk policy
• Ensuring our firewall and cyber protection remains up to date
• Limiting access to data to only those who need it
• Encryption of data ‘at rest’ and while in transit, for example by E-Mail, data stick, lap-tops etc.

Deletion of Data
In line with our data retention policy, we will ensure that once the compulsory retention period has passed, data will be destroyed/deleted securely.

Rights of the Data Subject
We recognise the rights of data subjects provided by the GDPR and these will at all times be respected.

Where a data subject wishes to exercise their right of access or rectification, this will be acted upon promptly but in all cases, no later than 30 days from the date of request. A charge may be made for providing the data subject with the information or the correction of any incorrect or inaccurate information we hold.

Breaches
The GDPR places on firms the obligation to notify the ICO of a breach where it is likely to result in a risk to the rights and freedoms of individuals. If unaddressed such a breach is likely to have a significant detrimental effect on individuals – for example, result in discrimination, damage to reputation, financial loss, loss of confidentiality or any other significant economic or social disadvantage.

Where a breach is likely to result in a high risk to the rights and freedoms of individuals, we must notify the data subject concerned directly.

A ‘high risk’ means the threshold for notifying individuals is higher than for notifying the ICO.

If a breach has been identified, it must be reported immediately to Anne Johnson who is responsible for investigating and reporting breaches. We have a system in place for reporting breaches in order to identify:
• How the breach occurred
• When it happened and how long it was happening for
• What categories of data were involved
• Number of records/data subjects affected
• How we have mitigated the breach

Once the above information has been obtained, but in all cases not longer than 72 hours from when we became aware of the breach, notification of the breach will be made by Anne Johnson to the ICO, and if appropriate, to the data subject.

This policy and processes arising from it are reviewed annually by Anne Johnson, Principal.