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Data Protection Policy

Last updated

July 2nd 2018

Definitions        

Organisation

means MSKnote, a company registered in England

GDPR

means the General Data Protection Regulation.

Responsible Person

means Tim Simms, MSKnote Data Protection Officer

Register of Systems

means a register of all systems or contexts in which personal data is processed by MSKnote.

1. Data protection principles

MSKnote is committed to processing data in accordance with its responsibilities under the Data Protection Legislation. 

The Data Protection Legislation requires that personal data shall be managed with:

  1. Lawfulness, fairness and transparency
  2. Purpose limitation
  3. Data minimisation
  4. Accuracy
  5. Storage limitation
  6. Integrity and confidentiality (security)
  7. Accountability

2. General provisions

  1. This policy applies to all personal data processed by MSKnote.
  2. The Responsible Person shall take responsibility for MSKnote’s ongoing compliance with this policy.
  3. This policy shall be reviewed at least annually.

3. Lawful, fair and transparent processing

  1. To ensure its processing of data is lawful, fair and transparent, MSKnote shall maintain a Register of Systems.
  2. The Register of Systems shall be reviewed at least annually.
  3. Individuals have the right to access their personal data and any such requests made to MSKnote in a Subject Access Request form, shall be dealt with in a timely manner.

4. Lawful purposes

  1. All data processed by MSKnote must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
  2. MSKnote shall note the appropriate lawful basis in the Register of Systems.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in  consent shall be kept with the personal data.
  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in MSKnote’s systems.  

5. Data minimisation

  1. MSKnote shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  2. MSKnote will store minimal personal data so as to allow for creation of a unique patient file on the clinical platform and patient app.

6. Accuracy

  1. MSKnote shall take reasonable steps to ensure personal data is accurate.
  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
  3. Clinical users of MSKnote’s system will also be accountable to ensure personal data is accurate.

7. Archiving / removal

  1. To ensure that personal data is kept for no longer than necessary, MSKnote shall follow their Data Retention policy for each area in which personal data is processed and review this process annually.
  2. The Data Retention  policy considers what data should/must be retained, for how long, and why.

8. Security

  1. MSKnote shall ensure that personal data is stored securely using modern software that is kept-up-to-date.  
  2. Access to personal data shall be limited to personnel who need access and appropriate security is in place to avoid unauthorised sharing of information.
  3. When personal data is deleted this should be done safely such that the data is irrecoverable.
  4. Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, MSKnote shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).

Appendix 1

Register of Systems

Subject Access Request Form

END OF POLICY

MSKnote Data Protection Policy 2018