Embrace Hair and Beauty has put this policy document together to reassure clients that the details you have shared with us are only used to create the best experiences in Hair and Beauty Services at Embrace Hair and Beauty only and nothing else.
Data Protection Policy
The GDPR requires us to process personal data securely. This is not a new data protection obligation.It replaces and mirrors the previous requirement to have ‘appropriate technical and organisationalmeasures’ under the Data Protection Act 1998 (the 1998 Act).
However, the GDPR provides more specifics about what we have to do about the security of your processing and what you as a clients has rights (Clients Rights- see list below) too are by ensuring that we minimise the risks of misuse of information and to put appropriate security measures in place. Whilst these are broadly equivalent to what was considered good and best practice under the 1998 Act, they are now a legal requirement.
This policy applies to clients, and customers both past and present if you fall into one of thesecategories then you are a ‘data subject’ for the purposes of this policy.
Embrace Hair and Beauty has taken steps to protect the security of your data in accordance with our ongoing Data Security Policy and will train staff about their data protection responsibilities as part of the induction process. We will only hold data for as long as necessary for the purposes for which we collected it.
Paper card consultations are destroyed immediately after input to our password protected data system or after 1 year if client has not returned in the case of ESPA treatments.
Penny Jelfs is the ‘data controller’ for the purposes of your personal data. This means that Penny Jelfs C/O Embrace Hair and Beauty determines the purpose and means of the processing of your personal data.
This policy explains how Embrace Hair and Beauty will hold and process your information. It explains your rights as a data subject.
Data Protection Principles
Personal data must be processed in accordance with six ‘Data Protection Principles.’ It must:
* be processed fairly, lawfully and transparently;
* be collected and processed only for specified, explicit and legitimate purposes;
* be adequate, relevant and limited to what is necessary for the purposes for which it is processed;
* be accurate and kept up to date. Any inaccurate data must be deleted or rectified without delay; * not be kept for longer than is necessary for the purposes for which it is processed; and
* be processed securely.
We are accountable for these principles and must be able to show that we are compliant.
How we define personal data
‘Personal data’ means information which relates to a living person who can be identified from that data (a ‘data subject’) on its own, or when taken together with other information which is likely tocome into our possession. It includes any expression of opinion about the person and an indication of the intentions of us or others, in respect of that person. It does not include anonymised data.
This policy applies to all personal data whether it is stored electronically, on paper or on other materials.
Your Name, Address, and Contact details including Email and Birthday. This is taken for usage by our team at Embrace on your first visit and is kept encrypted on our database securely held locally. This is held unless permission is not granted on the consultation form. The email address is added to our email data base and the mobile number is used for marketing messages including appointment reminders. This is auto generated by the Data Appointment System.(A,B)
Opting out of emails and Text needs to be done separately as the data is held is separate systems.(A,F)
Marketing Text messages will have an opt out on them after 25th May 2018.(A,F,E) Emails can be opted out at any time by unsubscribing.(A,F,D)
You may choose to be ‘forgotten’ by emailing email@example.com when your data will be deleted. This will automatically take place after 5 years if we have had no future bookings from you.(A,F,D)
We will not use your personal data for an unrelated purpose without telling you about it and the legal basis that we intend to rely on for processing it.(A,C,D)
Examples of when we might process your personal data could be an image of you used on social media for which your written consent will be sought. Either directly or by email. (A,B,C,D,E,F,G)
For example, we can do so if we have your explicit consent. If we asked for your consent to process a special category of personal data then we would explain the reasons for our request. You do not need to consent and can withdraw consent later if you choose by contacting the person for responsible for Data in the Company. (A,B,C,D,E,F,G)
Sharing your personal data
Sometimes we might share your personal data with group companies or our business partners, contractors and agents to carry out our obligations under our contract with you or for our legitimate interests. (A,D,E,F,G)
We require those companies to keep your personal data confidential and secure and to protect it in accordance with the law and their own privacy policies. They are only permitted to process your data for the lawful purpose for which it has been shared in accordance with their own privacy policies.
We use the following contractors to carry out our Company business: * Mail Chimp for email data services
* Salon Advantage for Appointment Collation Data
*Yotelecom for Phone and WIFI Services
We do not send your personal data outside the European Economic Area. If this changes you will be notified of this and the protections which are in place to protect the security of your data will be explained. (A,B,C,D,E,F,G)
How we process personal data for Embrace Hair and Beauty (A,B,C,D,E,F,G)
Everyone who works for, or on behalf of, Embrace Hair and Beauty has some responsibility for ensuring data is collected, stored and handled appropriately, in line with this policy and theCompany’s IT Security and Data Retention policies.
The Company’s Data Protection Manager, Penny Jelfs , is responsible for reviewing this policy on the Company’s data protection responsibilities and any risks in relation to the processing of data. Youshould direct any questions in relation to this policy or data protection to this person and address any written requests to them.
Employees should only access personal data covered by this policy if it is needed for services or relevant marketing on behalf of the Company and only if authorised to do so. They should only use the data for the specified lawful purpose for which it was obtained.
* should not share personal data informally.
* should keep personal data secure and not share it with unauthorised people.
* should regularly review and update personal data which you have to deal with for work.
* should not make unnecessary copies of personal data and should keep and dispose of any copies securely.
* should use strong passwords.
* should lock your computer screens when not at your desk.
* should not save personal data to your own personal computers or other devices.
* Personal data should never be transferred outside the European Economic Area except in compliance with the law and authorisation of the person for responsible for Data in your Company.
* should lock drawers and filing cabinets. Do not leave paper with personal data lying about.
* should not take personal data away from Company’s premises without authorisation from yourline manager or of the person for responsible for Data in your Company.
* Personal data should be shredded and disposed of securely when you have finished with it.
* You should ask for help from the person for responsible for Data in your Company if you are unsure about data protection or if you notice any areas of data protection or security we can improve upon.
* who deliberate or who are in negligent breach of this policy may result in disciplinary action being taken, in accordance with our disciplinary procedure.
* It is a criminal offence to conceal or destroy personal data which is part of a subject access request (see below). This conduct would also amount to gross misconduct under our disciplinary procedure, which could result in the employees dismissal.
Data Breaches (A,B,C,D,E,F,G)
We have robust measures in place to minimise and prevent data breaches from taking place. Should a breach of personal data occur (whether in respect of you or someone else) then we must take notes and keep evidence of that breach. If the breach is likely to result in a risk to the rights andfreedoms of individuals, then we must also notify the Information Commissioner’s Office within 72hours.
If you are aware of a data breach you must contact of the person for responsible for Data immediately and keep any evidence you have in relation to the breach.
Subject Access request (A,B,C,D,E,F,G)
Data subjects can make a ‘subject access request’ (‘SAR’) to find out the information we hold about them. This request must be made in writing to the person for responsible for Data in your Company who will coordinate a response.
If you would like to make a SAR in relation to your own personal data, you should make this in writing to the person for responsible for Data in the Company. We must respond within one month unless the request is complex or numerous in which case the period in which we must respond can be extended by a further two months.
There is no fee for making a SAR. However, if your request is manifestly unfounded or excessive we may charge a reasonable administrative fee or refuse to respond to your request.
Your data subject rights (Client Rights)
A.The right to be informed- You have the right to information about what personal data we process, how and on what basis as set out in this policy.
B. The right of access- You have the right to access your own personal data by way of a subject access request (see above).
C. The right to Rectification- You can correct any inaccuracies in your personal data. To do that you should contact of the person for responsible for Data in the Company, by email to firstname.lastname@example.org
D. The right to be forgotten- You have the right to request that we erase your personal data where we were not entitled under the law to process it or it is no longer necessary to process it for the purpose it was collected. To do so you should contact the person for responsible for Data in the Company. While you are requesting that your personal data is corrected or erased or are contesting the lawfulness of our processing, you can apply for its use to be restricted while the application is made. To do so you should contact the person for responsible for Data in the Company.
E. The right to data portability- You have the right to receive a copy of your personal data and to transfer your personal data to another data controller. We will not charge for this and will in most cases aim to do this within one month. With some exceptions, you have the right not to be subjected to automated decision-making.
F. The right to Object to Processing and Direct Marketing- You have the right to object to data processing where we are relying on a legitimate interest to do so and you think that your rights and interests outweigh our own and you wish us to stop.You have the right to object if we process your personal data for the purposes of direct marketing.
G. The right to be Notified- You have the right to be notified of a data security breach concerning your personal data.
You have the right to complain to the Information Commissioner. You can do this be contacting theInformation Commissioner’s Office directly. Full contact details including a helpline number can be found on the Information Commissioner’s Office website (www.ico.org.uk). This website has furtherinformation on your rights and our obligations
All client data is stored locally on our computer which is only accessible by staff members but who are in themselves under legal obligation to protect and keep the information secure. The database uses alpha numeric encryption. Which means that theft of this information is pointless due to the security needed to access it.
Clients information is requested to assist clients with appointment reminders and marketing activities – this information is of a minimum nature. Opt Out options will be included on marketing texts after 25May to insure compliance.
Clients who wish to receive Information by Email will do so by our provider Mail Chimp – means unsubscribe is available at any time, However unsubscribing from emails is separate from the text messaging service therefor clients should contact the salon directly to have data deleted- however details will automatically be deleted after 5 years in the case of non returners.