Data Protection Policy


1.1 Everyone has rights with regard to how their personal information is handled. During

the course of our activities we will collect, store and process personal information

about our staff, and we recognise the need to treat it in an appropriate and lawful


1.2 The types of information that we may be required to handle include details of current,

past and prospective employees, suppliers, customers and others that we communicate

with. The information, which may be held on paper or on a computer or other media, is

subject to certain legal safeguards specified in the Data Protection Act 1998 (the Act)

and other regulations. The Act imposes restrictions on how we may use that



2.1 This part of our handbook sets out our rules on data protection and the legal conditions

that must be satisfied in relation to the obtaining, handling, processing, storage,

transportation and destruction of personal information.

2.2 The Data Protection Compliance Manager is responsible for ensuring compliance with

the Act and with this part of our handbook. That post is held by Altin Biba, Medical

Team, 01277 212 797, Any questions or concerns about the

operation of this part of our handbook should be referred in the first instance to the

Data Protection Compliance Manager.

2.3 If you consider that our provisions for complying with the Act have not been followed

in respect of personal data about yourself or others you should raise the matter with

your line manager or the Data Protection Compliance Manager.


3.1 Data is information which is stored electronically, on a computer, or in certain paperbased filing systems.

3.2 Data subjects for the purpose of this policy include all living individuals about whom

we hold personal data. A data subject need not be a UK national or resident. All data

subjects have legal rights in relation to their personal data.

3.3 Personal data means data relating to a living individual who can be identified from that

data (or from that data and other information in our possession). Personal data can be

factual (such as a name, address or date of birth) or it can be an opinion (such as a

performance appraisal).

3.4 Data controllers are the people who or organisations which determine the purposes

for which, and the manner in which, any personal data is processed. They have a

responsibility to establish practices and policies in line with the Act. We are the data

controller of all personal data used in our business.

3.5 Data users include employees whose work involves using personal data. Data users

have a duty to protect the information they handle by following our data protection

and security policies at all times.

3.6 Data processors include any person who processes personal data on behalf of a data

controller. Employees of data controllers are excluded from this definition but it could

include suppliers which handle personal data on our behalf.

3.7 Processing is any activity that involves use of the data. It includes obtaining, recording

or holding the data, or carrying out any operation or set of operations on the data

including organising, amending, retrieving, using, disclosing, erasing or destroying it.

Processing also includes transferring personal data to third parties.

3.8 Sensitive personal data includes information about a person's racial or ethnic origin,

political opinions, religious or similar beliefs, trade union membership, physical or

mental health or condition or sexual life, or about the commission of, or proceedings

for, any offence committed or alleged to have been committed by that person, the

disposal of such proceedings or the sentence of any court in such proceedings.

Sensitive personal data can only be processed under strict conditions, and will usually

require the express consent of the person concerned.


4.1 Anyone processing personal data must comply with the eight enforceable principles of

good practice. These provide that personal data must be:

(a) Processed fairly and lawfully.

(b) Processed for limited purposes and in an appropriate way.

(c) Adequate, relevant and not excessive for the purpose.

(d) Accurate.

(e) Not kept longer than necessary for the purpose.

(f) Processed in line with data subjects' rights.

(g) Secure.

(h) Not transferred to people or organisations situated in countries without

adequate protection.

Fair and lawful processing

4.2 The Act is intended not to prevent the processing of personal data, but to ensure that it

is done fairly and without adversely affecting the rights of the data subject. The data

subject must be told who the data controller is (in this case ProMedical Personnel Ltd),

who the data controller's representative is (in this case the Data Protection

Compliance Manager), the purpose for which the data is to be processed by us, and the

identities of anyone to whom the data may be disclosed or transferred.

4.3 For personal data to be processed lawfully, certain conditions have to be met. These

may include, among other things, requirements that the data subject has consented to

the processing, or that the processing is necessary for the legitimate interest of the

data controller or the party to whom the data is disclosed. When sensitive personal

data is being processed, more than one condition must be met. In most cases the data

subject's explicit consent to the processing of such data will be required.

Processing for limited purposes

4.4 Personal data may only be processed for the specific purposes notified to the data

subject when the data was first collected or for any other purposes specifically

permitted by the Act. This means that personal data must not be collected for one

purpose and then used for another. If it becomes necessary to change the purpose for

which the data is processed, the data subject must be informed of the new purpose

before any processing occurs.

Adequate, relevant and non-excessive processing

4.5 Personal data should only be collected to the extent that it is required for the specific

purpose notified to the data subject. Any data which is not necessary for that purpose

should not be collected in the first place.

Accurate data

4.6 Personal data must be accurate and kept up to date. Information which is incorrect or

misleading is not accurate and steps should therefore be taken to check the accuracy of

any personal data at the point of collection and at regular intervals afterwards.

Inaccurate or out-of-date data should be destroyed.

Timely processing

4.7 Personal data should not be kept longer than is necessary for the purpose. This means

that data should be destroyed or erased from our systems when it is no longer

required. [For guidance on how long certain data is likely to be kept before being

destroyed, contact the Data Protection Compliance Manager.

Processing in line with data subject's rights

4.8 Data must be processed in line with data subjects' rights. Data subjects have a right to:

(a) Request access to any data held about them by a data controller.

(b) Prevent the processing of their data for direct-marketing purposes.

(c) Ask to have inaccurate data amended.

(d) Prevent processing that is likely to cause damage or distress to themselves or

anyone else.


5.1 We must ensure that appropriate security measures are taken against unlawful or

unauthorised processing of personal data, and against the accidental loss of, or damage

to, personal data. Data subjects may apply to the courts for compensation if they have

suffered damage from such a loss.

5.2 The Act requires us to put in place procedures and technologies to maintain the

security of all personal data from the point of collection to the point of destruction.

Personal data may only be transferred to a third-party data processor if he agrees to

comply with those procedures and policies, or if he puts in place adequate measures


5.3 Maintaining data security means guaranteeing the confidentiality, integrity and

availability of the personal data, defined as follows:

(a) Confidentiality means that only people who are authorised to use the data

can access it.

(b) Integrity means that personal data should be accurate and suitable for the

purpose for which it is processed.

(c) Availability means that authorised users should be able to access the data if

they need it for authorised purposes. Personal data should therefore be

stored on our central computer system instead of individual PCs.

5.4 Security procedures include:

(a) Entry controls. Any stranger seen in entry-controlled areas should be


(b) Secure lockable desks and cupboards. Desks and cupboards should be kept

locked if they hold confidential information of any kind. (Personal information

is always considered confidential.)

(c) Methods of disposal. Paper documents should be shredded. Floppy disks and

CD-ROMs should be physically destroyed when they are no longer required.

(d) Equipment. Data users should ensure that individual monitors do not show

confidential information to passers-by and that they log off from their PC

when it is left unattended.


6.1 A formal request from a data subject for information that we hold about them must be

made in writing. A fee is payable by the data subject for provision of this information.

Any member of staff who receives a written request should forward it to their line

manager OR the Data Protection Compliance Manager immediately.


7.1 Any member of staff dealing with telephone enquiries should be careful about

disclosing any personal information held by us. In particular they should:

(a) Check the caller's identity to make sure that information is only given to a

person who is entitled to it.

(b) Suggest that the caller put their request in writing if they are not sure about

the caller's identity and where their identity cannot be checked.

(c) Refer to their line manager OR the Data Protection Compliance Manager for

assistance in difficult situations. No-one should be bullied into disclosing

personal information.


Date Reviewed: January 2020