Data Protection Policy

Posture Group is a trading name of Relaxa UK Limited.


Introduction

Relaxa UK Limited is fully committed to compliance with the requirements of the Data Protection Act 1998 (“the Act”), which came into force on the 1st March 2000. Relaxa UK Limited will therefore follow procedures that aim to ensure that all employees, contractors and consultants of Relaxa UK Limited who have access to any personal data held by Relaxa UK Limited, are fully aware of and abide by their duties and responsibilities under the Act.

Statement of policy

In order to operate our software systems effectively, Relaxa UK Limited has to collect and use information about employees, consultants, agents and contractors of our customers with whom we work. This personal information must be handled and dealt with properly and there are safeguards within the Act to ensure this.

Relaxa UK Limited regards the lawful and correct treatment of personal information as very important to its successful operations and to maintaining confidence between Relaxa UK Limited and those with whom it carries out business. Relaxa UK Limited will ensure that it treats personal information lawfully and correctly.

To this end Relaxa UK Limited fully endorses and adheres to the Principles of Data Protection as set out in the Data Protection Act 1998 and have registered with the Information Commissioners Office.

The principles of data protection

The Act stipulates that anyone processing personal data must comply with Eight Principles of good practice. These Principles are legally enforceable.

The Principles require that personal information:

  1. Shall be processed fairly and lawfully and in particular, shall not be processed unless specific conditions are met;
  2. Shall be obtained only for one or more specified and lawful purposes and shall not be further processed in any manner incompatible with that purpose or those purposes;
  3. Shall be adequate, relevant and not excessive in relation to the purpose or purposes for which it is processed;
  4. Shall be accurate and where necessary, kept up to date;
  5. Shall not be kept for longer than is necessary for that purpose or those purposes;
  6. Shall be processed in accordance with the rights of data subjects under the Act;
  7. Shall be kept secure i.e. protected by an appropriate degree of security;
  8. Shall not be transferred to a country or territory outside the European
  9. Economic Area, unless that country or territory ensures an adequate level of data protection.


The Act provides conditions for the processing of any personal data. It also makes a distinction between personal data and ”sensitive” personal data.

Personal data is defined as, data relating to a living individual who can be identified from:

  • That data;
  • That data and other information which is in the possession of, or is likely to come into the possession of the data controller and includes an expression of opinion about the individual and any indication of the intentions of the data controller, or any other person in respect of the individual.


Sensitive personal data is defined as personal data consisting of information as to:

  • Racial or ethnic origin;
  • Political opinion;
  • Religious or other beliefs;
  • Trade union membership;
  • Physical or mental health or condition;
  • Sexual life;
  • Criminal proceedings or convictions.


Handling of personal/sensitive information

Relaxa UK Limited will, through appropriate management and the
use of strict criteria and controls:-

  • Observe fully conditions regarding the fair collection and use of personal information;
  • Meet its legal obligations to specify the purpose for which information is used;
  • Collect and process appropriate information and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements;
  • Ensure the quality of information used;
  • Apply strict checks to determine the length of time information is held;
  • Take appropriate technical and organisational security measures to safeguard personal information;
  • Ensure that personal information is not transferred abroad without suitable safeguards;
  • Ensure that the rights of people about whom the information is held can be fully exercised under the Act.


These include:

  • The right to be informed that processing is being undertaken;
  • The right of access to one’s personal information within the statutory 40 days;
  • The right to prevent processing in certain circumstances;
  • The right to correct, rectify, block or erase information regarded as wrong information.


In addition, Relaxa UK Limited will ensure that:

  • There is someone with specific responsibility for data protection in the organisation;
  • Everyone managing and handling personal information understands that they are contractually responsible for following good data protection practice;
  • Everyone managing and handling personal information is appropriately trained to do so;
  • Everyone managing and handling personal information is appropriately supervised;
  • Queries about handling personal information are promptly and courteously dealt with;
  • Methods of handling personal information are regularly assessed and evaluated;
  • Performance with handling personal information is regularly assessed and evaluated;


All employees are to be made fully aware of this policy and of their duties and responsibilities under the Act.

All managers and employees within Relaxa UK Limited will take steps to ensure that personal data is kept secure at all times against unauthorised or unlawful loss or disclosure and in particular will ensure that:

  • All files, records or documents containing personal/sensitive data are kept in a secure environment;
  • Personal data held on computers and computer systems is protected by the use of secure passwords, which where possible have forced changes periodically;
  • Individual passwords should be such that they are not easily compromised.


All contractors, consultants or employees of Relaxa UK Limited must:

  • Ensure that they and all of their staff who have access to personal data held or processed for or on behalf of Relaxa UK Limited, are aware of this policy and are fully trained in and are aware of their duties and responsibilities under the Act. Any breach of any provision of the Act will be deemed as being a breach of any contract between Relaxa UK Limited and the customer;
  • Allow data protection audits by Relaxa UK Limited of data held on its behalf (if requested);


Implementation

Relaxa UK Limited has appointed a Data Protection Information Officer. The officer will be responsible for ensuring that the Policy is implemented. Implementation will be led and monitored by the Information Officer. The Data Protection Information Officer will also have overall responsibility for:

  • The provision of data protection training, for staff within Relaxa UK Limited.
  • For the development of best practice guidelines.
  • For carrying out compliance checks to ensure adherence with the Data Protection Act.


Notification to the Information Commissioner

The Information Commissioner maintains a public register of data controllers. Relaxa UK Limited is registered as such.

The Data Protection Act 1998 requires every data controller who is processing personal data, to notify and renew their notification, on an annual basis. Failure to do so is a criminal offence.

To this end the designated officers will be responsible for notifying and updating the Information Officer of the processing of personal data.

Any changes to the register must be notified to the Information Commissioner, within 28 days.

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