Doc Fitness Data Protection Policy – *KEY POINTS
Lean42 operates http://www.docfitnessonline.com. This page informs you of our policies regarding the collection, use, and disclosure of Personal Information we receive from users of the Site. Lean42 will be referred to as Doc Fitness on this page for reference.
We use your Personal Information only for providing and improving the Site. By using the Site, you agree to the collection and use of information in accordance with this policy. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We keep certain basic information when you visit our website and recognise the importance of keeping that information secure and letting you know what we will do with it.
This policy only applies to docfitnessonline.com. If you leave our site via a link or otherwise, you will be subject to the policy of that website provider. We have no control over that policy or the terms of the website and you should check their policy before continuing to access the site.
Information we may collect from you;
We may collect and process the following data about you:
- Information that you provide by filling in forms on our site. This includes information provided at the time of registering to use our site, subscribing to our service or requesting further services. We may also ask you for information when you report a problem with our site.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of your visits to our site including, but not limited to, traffic data, location data, weblogs, operating system, browser usage and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
IP addresses and cookies
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual and we will not collect personal information in this way.
We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted through Stripe. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Uses made of the information
We use information held about you in the following ways:
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
- To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
- To carry out our obligations arising from any contracts entered into between you and us.
- To allow you to participate in interactive features of our service when you choose to do so.
- To notify you about changes to our service.
If you do not want us to use your data in this way, please tick the relevant box situated on the form on which we collect your data.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of €20 to meet our costs in providing you with details of the information we hold about you.
FULL Doc Fitness Data Protection Policy
The purpose of this page is to provide a concise policy statement regarding the Data Protection obligations of Doc Fitness. This includes obligations in dealing with personal data, in order to ensure that the organisation complies with the requirements of the relevant Irish legislation, namely the General Data Protection Regulation (GDPR) (2018), the Irish Data Protection Act (1988), and the Irish Data Protection (Amendment) Act (2003).
Doc Fitness must comply with the Data Protection principles set out in the relevant legislation. This Policy applies to all Personal Data collected, processed and stored by Doc Fitness in relation to its staff, service providers and clients in the course of its activities. Doc Fitness makes no distinction between the rights of Data Subjects who are employees, and those who are not. All are treated equally under this Policy.
The policy covers both personal and sensitive personal data held in relation to data subjects by Doc Fitness. The policy applies equally to personal data held in manual and automated form.
All Personal and Sensitive Personal Data will be treated with equal care by Doc Fitness. Both categories will be equally referred-to as Personal Data in this policy unless specifically stated otherwise.
This policy should be read in conjunction with the associated Subject Access Request procedure, the Data Retention and Destruction Policy, the Data Retention Periods List and the Data Loss Notification procedure.
Doc Fitness as a Data Controller
In the course of its daily organisational activities, Doc Fitness acquires, processes and stores personal data in relation to:
- Employees of Doc Fitness
- Clients of Doc Fitness
- Third-party service providers engaged by Doc Fitness
In accordance with the Irish Data Protection legislation, this data must be acquired and managed fairly. Not all staff members will be expected to be experts in Data Protection legislation. However, Doc Fitness is committed to ensuring that its staff have sufficient awareness of the legislation in order to be able to anticipate and identify a Data Protection issue, should one arise. In such circumstances, staff must ensure that the Data Protection Officer is informed, and in order, that appropriate corrective action is taken.
Due to the nature of the services provided by Doc Fitness, there is regular and active exchange of personal data between Doc Fitness and its Data Subjects. In addition, Doc Fitness exchanges personal data with Data Processors on the Data Subjects’ behalf.
This is consistent with Doc Fitness’s obligations under the terms of its contract with its Data Processors.
This policy provides the guidelines for this exchange of information, as well as the procedure to follow in the event that a Doc Fitness staff member is unsure whether such data can be disclosed.
In general terms, the staff member should consult with the Data Protection Officer to seek clarification.
Subject Access Requests
Any formal, written request by a Data Subject for a copy of their personal data (a Subject Access Request) will be referred, as soon as possible, to the Data Protection Officer, and will be processed as soon as possible.
It is intended that by complying with these guidelines, Doc Fitness will adhere to best practice regarding the applicable Data Protection legislation.
In the course of its role as Data Controller, Doc Fitness engages a number of Data Processors to process Personal Data on its behalf. In each case, a formal, written contract is in place with the Processor, outlining their obligations in relation to the Personal Data, the specific purpose or purposes for which they are engaged, and the understanding that they will process the data in compliance with the Irish Data Protection legislation.
These Data Processors include:
- Active Campaign Email Provider
- Go Cardless
- Google Drive
The Data Protection Principles
The following key principles are enshrined in the Irish legislation and are fundamental to the Doc Fitness’s Data Protection policy.
In its capacity as Data Controller, Doc Fitness ensures that all data shall:
- … be obtained and processed fairly and lawfully.
For data to be obtained fairly, the data subject will, at the time the data are being collected, be made aware of:
- The identity of the Data Controller (Doc Fitness)
- The purpose(s) for which the data is being collected
- The person(s) to whom the data may be disclosed by the Data Controller
- Any other information that is necessary so that the processing may be fair.
Doc Fitness will meet this obligation in the following way.
- Where possible, the informed consent of the Data Subject will be sought before their data is processed;
- Where it is not possible to seek consent, Doc Fitness will ensure that collection of the data is justified under one of the other lawful processing conditions – legal obligation, contractual necessity, etc.;
- Where Doc Fitness intends to record activity on CCTV or video, a Fair Processing Notice will be posted in full view;
- Processing of the personal data will be carried out only as part of Doc Fitness ’s lawful activities, and Doc Fitness will safeguard the rights and freedoms of the Data Subject;
- The Data Subject’s data will not be disclosed to a third party other than to a party contracted to Doc Fitness and operating on its behalf.
- …. be obtained only for one or more specified, legitimate purposes.
Doc Fitness will obtain data for purposes which are specific, lawful and clearly stated. A Data Subject will have the right to question the purpose(s) for which Doc Fitness holds their data, and Doc Fitness will be able to clearly state that purpose or purposes.
- ….. not be further processed in a manner incompatible with the specified purpose(s).
Any use of the data by Doc Fitness will be compatible with the purposes for which the data was acquired.
- …. be kept safe and secure.
Doc Fitness will employ high standards of security in order to protect the personal data under its care. Appropriate security measures will be taken to protect against unauthorised access to, or alteration, destruction or disclosure of any personal data held by Doc Fitness in its capacity as Data Controller.
Access to and management of staff and customer records is limited to those staff members who have appropriate authorisation and password access.
- … be kept accurate, complete and up-to-date where necessary.
Doc Fitness will:
- ensure that administrative and IT validation processes are in place to conduct regular assessments of data accuracy;
- conduct periodic reviews and audits to ensure that relevant data is kept accurate and up-to-date. Doc Fitness conducts a review of sample data every six months to ensure accuracy; Staff contact details and details on next-of-kin are reviewed and updated every two years.
- conduct regular assessments in order to establish the need to keep certain Personal Data.
- … be adequate, relevant and not excessive in relation to the purpose(s) for which the data were collected and processed.
Doc Fitness will ensure that the data it processes in relation to Data Subjects are relevant to the purposes for which those data are collected. Data which are not relevant to such processing will not be acquired or maintained.
- … not be kept for longer than is necessary to satisfy the specified purpose(s).
Doc Fitness has identified an extensive matrix of data categories, with reference to the appropriate data retention period for each category. The matrix applies to data in both a manual and automated format.
Once the respective retention period has elapsed, Doc Fitness undertakes to destroy, erase or otherwise put this data beyond use.
- … be managed and stored in such a manner that, in the event a Data Subject submits a valid Subject Access Request seeking a copy of their Personal Data, this data can be readily retrieved and provided to them.
Doc Fitness has implemented a Subject Access Request procedure by which to manage such requests in an efficient and timely manner, within the timelines stipulated in the legislation.
Data Subject Access Requests
As part of the day-to-day operation of the organisation, Doc Fitness’s staff engage in active and regular exchanges of information with Data Subjects. Where a formal request is submitted by a Data Subject in relation to the data held by Doc Fitness, such a request gives rise to access rights in favour of the Data Subject.
There are specific timelines within which Doc Fitness must respond to the Data Subject, depending on the nature and extent of the request. These are outlined our Subject Access Request process document which you can request.
Doc Fitness’s staff will ensure that, where necessary, such requests are forwarded to the Data Protection Officer in a timely manner, and they are processed as quickly and efficiently as possible, but within not more than 40 days from receipt of the request.
As a Data Controller, Doc Fitness ensures that any entity which processes Personal Data on its behalf (a Data Processor) does so in a manner compliant with the Data Protection legislation.
Failure of a Data Processor to manage Doc Fitness’s data in a compliant manner will be viewed as a breach of contract, and will be pursued through the courts.
Failure of Doc Fitness’s staff to process Personal Data in compliance with this policy may result in disciplinary proceedings.
For the avoidance of doubt, and for consistency in terminology, the following definitions will apply within this Policy.
|Data||This includes both automated and manual data.
Automated data means data held on computer, or stored with the intention that it is processed on a computer.
Manual data means data that is processed as part of a relevant filing system, or which is stored with the intention that it forms part of a relevant filing system.
|Personal Data||Information which relates to a living individual, who can be identified either directly from that data, or indirectly in conjunction with other data which is likely to come into the legitimate possession of the Data Controller. (If in doubt, Doc Fitness refers to the definition issued by the Article 29 Working Party, and updated from time to time.)|
|Sensitive Personal Data||A particular category of Personal data, relating to: Racial or Ethnic Origin, Political Opinions, Religious, Ideological or Philosophical beliefs, Trade Union membership, Information relating to mental or physical health, information in relation to one’s Sexual Orientation, information in relation to commission of a crime and information relating to conviction for a criminal offence.|
|Data Controller||A person or entity who, either alone or with others, controls the content and use of Personal Data by determining the purposes and means by which that Personal Data is processed.|
|Data Subject||A living individual who is the subject of the Personal Data, i.e. to whom the data relates either directly or indirectly.|
|Data Processor||A person or entity who processes Personal Data on behalf of a Data Controller on the basis of a formal, written contract, but who is not an employee of the Data Controller, processing such Data in the course of his/her employment.|
|Data Protection Officer||A person appointed by Doc Fitness to monitor compliance with the appropriate Data Protection legislation, to deal with Subject Access Requests, and to respond to Data Protection queries from staff members and service recipients|
|Relevant Filing System||Any set of information in relation to living individuals which is not processed by means of equipment operating automatically (computers), and that is structured, either by reference to individuals, or by reference to criteria relating to individuals, in such a manner that specific information relating to an individual is readily retrievable.|
*Updated according to GDPR: 18/05/18