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Data Privacy and Cyber Protection Policy 

1. Introduction 

1.1. This Data Protection Policy is the overarching policy for data security and protection for Cardiologic  Ltd (hereafter referred to as "us", "we", or "our").  

2. Purpose 

2.1. The purpose of the Data Protection Policy is to support the 10 Data Security Standards, the General  Data Protection Regulation (2016), the Data Protection Act (2018), the common law duty of  confidentiality and all other relevant national legislation. We recognise data protection as a fundamental  right and embrace the principles of data protection by design and by default. 

2.2. This policy covers our data protection principles and commitment to common law and legislative compliance  procedures for data protection by design and by default. 

3. Scope 

3.1. This policy includes in its scope all data which we process either in hardcopy or digital copy, this  includes special categories of data. 

3.2. This policy applies to all staff, including temporary staff and contractors.  

4. Principles 

4.1. We will be open and transparent with service users and those who lawfully act on their behalf in  relation to their care and treatment. We will adhere to our duty of candor responsibilities as outlined in  the Health and Social Care Act 2012. 

4.2. We will establish and maintain policies to ensure compliance with the Data Protection Act 2018,  Human Rights Act 1998, the common law duty of confidentiality, the General Data Protection Regulation  and all other relevant legislation. 

4.3. We will establish and maintain policies for the controlled and appropriate sharing of service user and  staff information with other agencies, taking account all relevant legislation and citizen consent.

4.4. Where consent is required for the processing of personal data we will ensure that informed and  explicit consent will be obtained and documented in clear, accessible language and in an appropriate  format. The individual can withdraw consent at any time through processes which have been explained  to them and which are outlined in our Record Keeping Policy: Withdrawal of Consent procedures. We  ensure that it is as easy to withdraw as to give consent.  

4.5. We will undertake annual audits of our compliance with legal  requirements. 

4.6. We acknowledge our accountability in ensuring that personal data shall be: 

4.6.1. Processed lawfully, fairly and in a transparent manner; 

4.6.2. Collected for specified, explicit and legitimate purposes and not further processed in a  manner that is incompatible with those purposes; 

4.6.3. Adequate, relevant and limited to what is necessary in relation to the purposes for which  they are processed (‘data minimisation’); 

4.6.4. Accurate and kept up to date; 

4.6.5. 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 (‘storage limitation’); 

4.6.6. Processed in a manner that ensures appropriate security of the personal data. 

4.7. We uphold the personal data rights outlined in the GDPR; 

4.7.1. The right to be informed; 

4.7.2. The right of access; 

4.7.3. The right to rectification; 

4.7.4. The right to erasure; 

4.7.5. The right to restrict processing; 

4.7.6. The right to data portability; 

4.7.7. The right to object; 

4.7.8. Rights in relation to automated decision making and profiling. 


Due to our size, we have determined that we are not required to have a Data Protection Officer (DPO), as  we do not process special categories of data on a large scale. Nonetheless, to ensure that individuals' data rights are respected and that there are the highest levels of data security and protection  in our organisation, we have appointed a member of staff to be our Data Security and Protection Lead.  The Data Security and Protection Lead will report to the highest management level of the organisation.  We will support the Data Security and Protection Lead with the necessary resources to carry out their  tasks and ensure that they can maintain expertise. 

5. Data protection by design & by default 

5.1. We shall implement appropriate organisational and technical measures to uphold the principles  outlined above. We will integrate necessary safeguards to any data processing to meet regulatory  requirements and to protect individual’s data rights. This implementation will consider the nature, scope,  purpose and context of any processing and the risks to the rights and freedoms of individuals caused by  the processing. 

5.2. We shall uphold the principles of data protection by design and by default from the beginning of any  data processing and during the planning and implementation of any new data process. 

5.3. Prior to starting any new data processing, we will assess whether we should complete a Data  Protection Impact Assessment (DPIA) using the ICO’s screening checklist.

5.4. All new systems used for data processing will have data protection built in from the beginning of the  system change. 

5.5. All existing data processing has been recorded on our Record of Processing Activities. Each process  has been risk assessed and is reviewed annually. 

5.6. We ensure that, by default, personal data is only processed when necessary for specific purposes  and that individuals are therefore protected against privacy risks. 

5.7. In all processing of personal data, we use the least amount of identifiable data necessary to  complete the work it is required for and we only keep the information for as long as it is required for the  purposes of processing or any other legal requirement to retain it. 

5.8. Where possible, we will use pseudonymised data to protect the privacy and confidentiality of our  staff and those we support.  

6. Responsibilities 

6.1. Our designated Data Security and Protection Lead is Lara Peat. The key responsibilities of the lead  are: 

6.1.1. To ensure the rights of individuals in terms of their personal data are upheld in all instances  and that data collection, sharing and storage is in line with the Caldicott Principles; 

6.1.2. To define our data protection policy and procedures and all related policies, procedures and  processes and to ensure that sufficient resources are provided to support the policy requirements. 

6.1.3. To complete the Data Security & Protection Toolkit (DSPT) annually and to maintain  compliance with the DSPT. 

6.1.4. To monitor information handling to ensure compliance with law, guidance and the  organisation’s procedures and liaising with senior management to fulfil this work.  

6.2. Other  key responsibilities are: 

6.2.1. Overseeing changes to systems and processes; 

6.2.2. Monitoring compliance with the GDPR and the Data Protection Act 2018; 

6.2.3. Completing DPIA; 

6.2.4. Reporting on data protection and compliance with legislation to senior management;

6.2.5. Liaising, if required, with the Information Commissioner’s Office (ICO). 

7. Approval 

7.1. This policy has been approved by the undersigned and will be reviewed at least annually.  

Martyn Dixon 

Managing Director 9.1.2022 

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