Data Protection Policy

Introduction

This Policy sets out the obligations of Hampton Clinic (“the Company”) regarding data protection and the rights of clients (“data subjects”) in respect of their personal data under the General Data Protection Regulation (EU) 2016/679 (the “Regulation”).

The Regulation defines “personal data” as any information relating to an identified or identifiable natural person (a data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

This Policy sets out the procedures that are to be followed when dealing with personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

The Data Protection Principles

This Policy aims to ensure compliance with the Regulation. The Regulation sets out the following principles with which any party handling personal data must comply. All personal data must be:

Processed lawfully, fairly, and in a transparent manner in relation to the data subject.

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

Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate is erased or rectified without delay.

Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed.

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.

Lawful, Fair, and Transparent Data Processing

The Regulation seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. Processing of personal data is lawful if at least one of the following applies:

The data subject has given consent to the processing of their personal data for one or more specific purposes.

Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.

Processing is necessary for compliance with a legal obligation to which the controller is subject.

Processing is necessary to protect the vital interests of the data subject or of another natural person.

Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject.

Adequate, Relevant and Limited Data Processing

The Company will only collect and process personal data for and to the extent necessary for the specific purpose(s) informed to data subjects.

Accuracy of Data and Keeping Data Up To Date

The Company shall ensure that all personal data collected and processed is kept accurate and up-to-date. The accuracy of data shall be checked when it is collected and at regular intervals thereafter.

Timely Processing

The Company shall not keep personal data for any longer than is necessary in light of the purposes for which that data was originally collected and processed. When the data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.

Secure Processing

The Company shall ensure that all personal data collected and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage. Further details of the data protection and organisational measures which shall be taken are provided in later parts of this Policy.

Accountability

The Company’s data protection officer is Kelly Briggs, [email protected].

The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information: the name and details of the Company, its data protection officer, and any applicable third-party data controllers; the purposes for which the Company processes personal data; details of the categories of personal data collected, held, and processed by the Company; details of any third parties that will receive personal data from the Company; details of any transfers of personal data to non-EEA countries; details of how long personal data will be retained; and detailed descriptions of all technical and organisational measures taken to ensure the security of personal data.

The Rights of Data Subjects

The Regulation sets out the following rights applicable to data subjects: the right to be informed; the right of access; the right to rectification; the right to erasure (also known as the ‘right to be forgotten’); the right to restrict processing; the right to data portability; the right to object; and rights with respect to automated decision-making and profiling.

Data Subject Access

A data subject may make a subject access request (“SAR”) at any time to find out more about the personal data which the Company holds about them. The Company is normally required to respond to SARs within one month of receipt.

All subject access requests received must be forwarded to Kelly Briggs, the Company’s data protection officer, at [email protected].

The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive.

Rectification of Personal Data

If a data subject informs the Company that personal data held by the Company is inaccurate or incomplete, requesting that it be rectified, the personal data in question shall be rectified, and the data subject informed of that rectification, within one month of receipt of the data subject’s notice.

Erasure of Personal Data

Data subjects may request that the Company erases the personal data it holds about them in the following circumstances: it is no longer necessary for the Company to hold that personal data with respect to the purpose for which it was originally collected or processed; the data subject wishes to withdraw their consent; the data subject objects to the Company holding and processing their personal data; the personal data has been processed unlawfully; or the personal data needs to be erased in order for the Company to comply with a particular legal obligation.

Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request.

Contact

For any questions or concerns regarding this Data Protection Policy, or to exercise your data protection rights, please contact our Data Protection Officer: Kelly Briggs at [email protected].