Privacy Policy

Policy Statement

The purpose of this policy is to protect, to consistently high standards, all information assets including service users, residents, staff, records written or electronic and all other corporate information, from all potentially damaging threats, internal or external, deliberate or accidental, imagined or real. Until the advent of the internet, cyber was used in the information of words relating to computers, computer networks, or virtual reality. From the Wall Street Journal to Doctor Who cyber has developed into the English language where it is currently associated with the Internet and other developing technologies. Mass cyber attacks are almost always via Internet providers data systems which are hacked and often the data is leaked into the mainstream media outlets. Governments now issue lots of guidance regarding cyber breaches of data protection laws and this policy reflects much of the guidance.

The Policy

Where information security is cited, it includes cyber security and visa versa.

Information security is primarily about people, but is facilitated by the appropriate use of technology, which is evermore sophisticated and evolving in its nature.

This policy applies to all aspects of information handling, including, but not limited to

  • structured record systems – paper and electronic
  • information recording and processing systems – paper, electronic, video, photographic and audio recordings
  • information transformation systems such as fax, email, portable media, post and telephone

The purpose of the policy is to achieve a consistent approach to the security management of information throughout the organisation, in order to enable continual business capability and to minimise the likelihood of occurrence and the impact of any information security incident or breach

Process Requirements

Information security is paramount in maintaining and protecting the confidentiality, integrity and availability, where appropriate, to the organisations information or data. There are 3 elements to the process

  • maintain the confidentiality of personal information including customers and staff by protecting it in accordance with all legal and regulatory framework criteria
  • ensure the integrity of the organisations information by developing, monitoring and maintaining it to a satisfactory level of quality for use within the relevant activity area
  • review and implement the necessary measures to maintain availability of the organisations information systems and services, including putting in place contingency measures which ensures the minimum of disruption, should an incident or breach occur

Physical Security

The physical security of information is the responsibility of everyone who is involved in the handling, maintaining, storage, retrieval, including any information which is shared, transmitted electronically or transported by external suppliers e.g. courier services and postal deliveries. Staff at all levels throughout the organisation must take all necessary precautions to avoid loss, theft, damage or misappropriation of information.

The following good practice is in place.

  • all staff must wear I.D. badges; individuals not doing so, in non-public areas should  be challenged
  • visitors must sign in, be met at reception and accompanied at all times
  • all doors must be properly secured and where used, entry codes must be regularly changed to protect their integrity
  • anyone loitering or obviously out of place should be asked their purpose of visit etc and checked accordingly
  • in order to prevent a malware contamination, no external hardware such as USB, Memory or Recording Portable Devices can be used within the organisations, without prior approval from Luke Donohue
  • Management of computers and/or networks is controlled via a contractual arrangement with Computers Dot Com 6 Edison Rd Churchfields Salisbury SP2 7NU Tel: 01722 343640 I.T. team.
  • users, shall not install software, for any purpose, unless authorised to do so by the managing director Users who breach this requirement may be subject to disciplinary action
  • screens should be locked when unattended even for short periods, such as toilet breaks
  • passwords should never be shared and changed at regular intervals
  • disposal of equipment is allowed only by authorised personnel
  • secure transfer of files and documentation whether physically or electronically, must be properly recorded and approved
  • should a legitimate need arise for a non-routine transfer of information, a risk assessment must be undertaken first to determine the most secure transfer process e.g. courier, by hand only, etc
  • adequate and appropriate monitoring of information that is held and its use, should be undertaken at least annually, as part of the audit cycle
  • records management systems, policies and procedures should be followed at all times, within the information chain
  • paper information is particularly vulnerable, for instance, person identifiable, sensitive personal information should be removed or covered when left unattended on desks or work surfaces
  • a clear desk routine should be followed, with a final check in place at the end of the working day, which includes paper vulnerability and computer security

Business continuity is assured by continually reviewing our information systems, in particular;

  • that information shall be available to properly authorised personnel as and when it is required
  • relevant information security awareness and training is regularly available and accessible to staff
  • all breaches of information security, actual or suspected are recorded, reported and investigated and mitigating measures put into place to prevent a re-occurrence

Potential or Actual Security Breaches

  • all staff within this organisation are responsible for ensuring that no potential or actual security breaches occur as a result of their actions.
  • on receipt of a reported breach, an investigation with a report, in a timescale appropriate to the risks to the business, will be completed by the managing director.
  • notifications to any Regulatory body will be part of this process, where necessary

Risk to the business is directly linked to our capacity to remain secure and any such measures must be viewed as necessary protection against any event occurring A range of security measures can be deployed to address:

  • the Threat of something damaging the confidentiality, integrity or availability of information held or systems or manual records
  • the Impact that such a threat would have
  • the likelihood of such a threat occurring

To mitigate risks, we will work towards a “paperlite” environment as outlined in our business

Information Sharing Guidance

This clarifies information sharing for staff at all levels of the organisation. Where staff are in any doubt as to whether it is appropriate to share information, advice should be sought from the data controller. Luke Donohue Managing Director.

Information Sharing Principles

  • Must have lawful authority
  • Must be necessary
  • Must be proportionate
  • Must need to know
  • Must be accountable
  • Must ensure the safety and security of the information shared

We are all aware of the intense media interest particularly when things go wrong, so a balanced approach to information sharing is vital in any decision to share. In safeguarding situations particularly, it is important to ask why you wouldn’t share. All health and social care staff and partner agencies have a common law duty of confidentially within their work with Adults at risk. They also have a duty to comply with the Caldicott principles.

These are a set of requirements that ensure that information regarding people who use services is treated with sensitivity to maintain its confidentiality. Information that has been provided in confidence is not normally shared or used without consent from the subject and source of such information. In all cases the main legislation which underpins the sharing of information in relation to adults at risk is:

  • Common law duty of confidentiality
  • Data Protection legislation
  • Human Rights Act 1998
  • Freedom of Information Act 2000
  • Crime and Disorder Act 1998
  • Care Act 2014

It is requirement that all staff of this organisation adhere to the Golden Rules, set out below, for information sharing in all instances of information Exchange between all multi-agency partners external contacts and any request for such information will only be shared when all the Golden Rules are met.

The Golden Rules

  • remember that the data protection act is not a barrier to sharing information but provides a framework to ensure that personal information about living persons is shared appropriately
  • be open and honest with the person, family or representative from the outset about why, what, how and with whom information will or could be shared and seek their agreement unless it is unsafe or inappropriate to do so
  • seek advice, if you are in any doubt, and where this is outside of the organisation, remember confidentiality
  • share with consent, where appropriate and where possible, respect the wishes of those who do not consent to share confidential information
  • you may still share information, without consent, if, in your judgement, that lack of consent can be overridden in the public interest. you will need to base such judgements on the facts of the case
  • consider safety and wellbeing: base your information sharing decisions on considerations of the safety and wellbeing of the person and others who may be affected by their actions
  • adhere to all policies regarding transporting of confidential and sensitive information including staff records

Related Policies

Co-operating with other Providers
Data Protection Legislative Framework (GDPR)
Internet and Email
Media and Public Relations
Record Keeping
Social Media and Networking


Date Reviewed: June 2022

Person responsible for updating this policy: Donna Malone

Next Review Date: June 2023

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