DATA PROTECTION NOTICE
Ashlawn House Nursing Home may have to collect and use information about people with whom we work. These may include residents and their family members, current, past and prospective employees, clients, and suppliers. This personal information must be handled and dealt with properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means.
We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business. We will ensure that we treat personal information lawfully and correctly.
To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR). GDPR applies to the processing of personal data in manual and electronic records kept by us in connection with its human resources function as described below. It also covers our response to any data breach and other rights under the GDPR.
Personal data is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data. Data processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
- processing will be fair, lawful and transparent
- data be collected for specific, explicit, and legitimate purposes
- data collected will be adequate, relevant and limited to what is necessary for the purposes of processing
- data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
- data is not kept for longer than is necessary for its given purpose
- data will be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
TYPES OF DATA HELD
We keep several categories of personal data in order to carry out effective and efficient processes. We keep this data in files relating to each person and we also hold the data within our computer systems, for example, EpicCare and our payroll system.
Typical forms of data are:
- personal details such as name, address, phone numbers and email addresses.
- information gathered regarding medical and health information from individuals including third party information that is critical to on going care
- details relating to administration such as PPS numbers, bank account details and tax codes insurance policy numbers, GP and Medical Card numbers
- CCTV is in operation throughout our premises in the interest of safety to residents and staff
- Data regarding our suppliers and their contact details.
- All of the above information is required for our processing activities. More information on those processing activities are available from Ashlawn House.
PERSONAL INFORMATION RIGHTS
You have the following rights in relation to the personal data we hold on you
- the right to be informed about the data we hold on you and what we do with it.
- the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected and updated.
- the right to have data deleted in certain circumstances. This is also known as ‘erasure’
- the right to restrict the processing of the data;
- the right to transfer the data we hold on you to another party.
- the right to object to the inclusion of any information;
- the right to regulate any automated decision-making and profiling of personal data.
ACCESS TO DATA
Data Subjects have a right to access the personal data that we hold on them. To exercise this right, the Data Subject should make a request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit. No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the Data Subject making the request. In these circumstances, a reasonable charge will be applied.
All our Data Subjects are aware that personal information should be kept in a locked office, filing cabinet, drawer, or safe. Staff are aware of their roles and responsibilities when their role involves the processing of data. All staff are instructed to store files or written information of a confidential nature in a secure manner so that are only accessed by people who have a need and a right to access them and to ensure that screen locks are implemented on all PCs, laptops etc when unattended. No files or written information of a confidential nature are to be left where they can be read by unauthorised people.
Where data is computerised, it should be coded, encrypted or password protected both on a local hard drive and on a network drive that is regularly backed up. Staff must always use the passwords provided to access the computer system and not abuse them by passing them on to people who should not have them.
Personal data relating to Data Subjects should not be kept or transported on laptops, USB sticks, or similar devices, unless prior authorisation has been received. Where personal data is recorded on any such device it should be protected by (a)ensuring that data is recorded on such devices only where absolutely necessary (b)using an encrypted system a folder should be created to store the files that need extra protection and all files created or moved to this folder should be automatically encrypted and (c)ensuring that laptops or USB drives are not left where they can be stolen.
THIRD PARTY PROCESSING
Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data.
REQUIREMENT TO NOTIFY BREACHES
All data breaches will be recorded and where legally required, we will report a breach to the Data Protection Commission within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.
MAKING A COMPLAINT
If you think your data rights have been breached, you are able to raise a complaint with the Office of the Data Protection Commissioner. You can contact the ODPC at Data Protection Commissioner, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois or by telephone on +353 57 8684800 or +353 (0)761 104 800 or Lo Call 1890 252 231 or email firstname.lastname@example.org.
DATA PROTECTION COMPLIANCE
Our Controller in respect of our data protection activities can be contacted at the following
Ashlawn House Nursing Home,
Phone 06731433 or
e-mail : email@example.com.
UPDATES TO THE NOTICE
Please note that changes to this notice can be made from time to time on use of information or updates in technology and products