Pharmacy2U Ltd. needs to gather, store and use certain information about individuals.
These can include stakeholders eg: customers, suppliers, business contacts, employees and other people in the organisation or anyone who has a relationship with or may need to contact Pharmacy2U.
This policy describes how this personal data must be collected, handled, stored and when appropriate deleted, to meet the company’s data protection standards and to comply with UK or EU law.
Why this policy exists
- Pharmacy2U places the patient / customer as the focus of its interest
- Complies with data protection law and follows good practice
- Protects the rights of staff, customers and partners
- Is open about how it stores and processes individual’ data
- Protects itself from the risks of a data breach
- Regularly “cleans” its list
A) Data protection law
- The Data Protection Act 1998 describes how organisations including Pharmacy2U Ltd. must collect, handle and store personal information
- These rules apply regardless of whether data is stored electronically, on paper or on other materials
- To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully
- The data Protection Act is underpinned by eight important principles. These say that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
- Not be transferred outside the European Economic Area, unless the country or territory also ensures an adequate level of protection
B) People, risks and responsibilities
- This policy applies to:
- The head office of Pharmacy2U Ltd.
- All branches and warehouses of Pharmacy2U Ltd.
- All staff and volunteers of Pharmacy2U Ltd.
- All contractors, suppliers and other people working on behalf of Pharmacy2U Ltd.
- It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:
- Ages of individuals
- Names of individuals
- Postal addresses
- Email addresses
- Telephone number
- Patients prescription and purchasing data
C) Data protection risks
- This policy helps to protect Pharmacy2U Ltd. From some very real data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately
- Failing to offer choice. For instance, all instances should be free to choose how the company uses data relating to them
- Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data. Financial data is particularly vulnerable and Pharmacy2U should endeavour to store such data off site
- Everyone who works for or with Pharmacy2U Ltd. Has some responsibility for ensuring data is collected, stored and handled appropriately
- Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles
- However, these people have key areas of responsibility:
- The board of directors are ultimately responsible for policies that ensure that Pharmacy2U Ltd meets its legal obligations. Thus any changes in SOPs must be approved by the Board.
- The data protection officer, Daniel Lee is responsible for:
- Keeping the board updated about the data protection responsibilities, risks and issues
- Reviewing all data protection procedures and related policies, in line with an agreed schedule.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and anyone else covered by this policy
- Dealing with requests from individuals to see the data Pharmacy2U Ltd. Holds about them (subject access requests).
- Checking and approving any contacts or agreements with third parties that may handle the company’s sensitive data.
- Ensuring that Pharmacy2U’s privacy statements abide by the law.
- Gaining Board approval for any new proposal for the utilisation of data.
- The Head of IT, Steven Dobson, is responsible for:
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards
- Performing regular checks and scans to ensure security hardware and software is functioning properly
- Evaluating third-party services the company is using to store or process data. For instance, cloud computing services.
- Constantly simulating “cyber attacks” to ensure Pharmacy2U’s systems are secure.
- The Chief Marketing Officer, Maya Moufarek, is responsible for:
- Approving any data protection statements attached to communications such as emails and letters
- Addressing any data protection queries from journalists or media outlets such as newspapers
E) General staff guidelines
- The only people able to access data covered by this policy should be those who need it for their work. Data will only be provided on a “need to know” basis
- Data should not be shared informally. When access to confidential information is required, employees can request it from their managers
- Pharmacy2U Ltd. Will provide training to all employees to help them understand their responsibilities when handling data
- Employees should keep all data secure, by taking sensible precautions and following the guidelines below
- In particular, strong passwords must be used and they should never be shared
- Personal data should not be disclosed to unauthorised people, either within the company or externally
- Data should be regularly reviewed and updated if it found to be out of date. If no longer required, it should be deleted and disposed of
- Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
F) Data storage
- These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Head of IT or data controller
- When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it
- These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
- When not required, the paper or files should be kept in a locked draw or filing cabinet
- Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer
- Data printouts should be shredded and disposed of securely when no longer required
- When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
- Data should be protected by strong passwords that are changed regularly and never shared between employees
- If data is stored on removable media, these should be kept locked away securely when not being used
- Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services
- Servers containing personal data should be sited in a secure location, away from the general office space
- Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures
- Data should never be saved directly to laptops or other mobile devices like tablets or smart phones
- All servers and computers containing data should be protected by approved security software and a firewall
- Encryption of data is planned to become the norm.
G) Data use
- Personal data is of no value to Pharmacy2U Ltd unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
- When working with personal data, employees should ensure the screens of their computers are always locked when left unattended
- Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure
- Data must be encrypted before being transferred electronically. The Head of IT can explain how to send data to authorised external contacts
- Personal data should never be transferred outside of the European Economic Area
- Employees should not save copies of personal data on their own computers. Always access and update the central copy of any data.
H) Data accuracy
- The law requires Pharmacy2U Ltd to take reasonable steps to ensure data is kept accurate and up to date
- The more important it is that the personal data is accurate, the greater the effort Pharmacy2U Ltd should put into ensuring its accuracy
- It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept accurate and up to date as possible
- Data will be held in as few places as necessary. These places are defined as secure data depositories. Staff should not create any unnecessary additional data sets
- Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call
- Pharmacy2U Ltd. will make it easy for data subjects to update the information Pharmacy2U Ltd. holds about them. For instance, via the company website
- Data should be updated as inaccuracies are discovered. For instance, if a cusomter can not longer be reached on their stored telephone number, it should be removed from the database
- It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months
- All databases are to be cleaned at every opportunity and at least every six months, through a planned process.
I) Subject access requests
- All individual whoare the subject of personal data held by Pharmacy2U Ltd. are entitled to:
- Ask what information the company holds about them and why
- Ask how to gain access to it
- Be informed how to keep it up to date
- Be informed how the company is meeting its data protection obligations
- If an individual contacts the company requesting this information, this is called a subject access request
- Subject access requests from individuals should be made by email, addresses to the Data Protection Officer firstname.lastname@example.org. The Data Protection Officer can supply a standard request form, although individuals do not have to use this
- The Data Protection Officer will always verify the identity of anyone making a subject access request before handling over any information.
J) Disclosing data for other reasons
- In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject
- Under these circumstances, Pharmacy2U Ltd. will disclose requested data. However, the Data Protection Officer will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisors where necessary.
K) Providing information
- Pharmacy2U Ltd. aims to ensure that individuals are aware that their data is beingprocessed, and that they understand:
- How the data is being used
- How to exercise their rights
This information is published on the Pharmacy2U website.