Netcare Europe Limited (“we,” “us,” or “our”) is committed to a policy protecting the rights and privacy of individuals, including full and part time staff, suppliers and others, in accordance with the General Data Protection Regulation (GDPR) and Data Protection Act 2018. This regulatory environment demands transparency and accountability in how companies manage and use personal data. It also accords new and stronger rights for individuals to understand and control that use.

This GDPR and Privacy Policy contains the provisions that our Company must be aware of as data controllers, including provisions intended to enhance the protection of full and part time staff’s personal data.

General Data Protection Regulation (GDPR)

This piece of legislation came into force in May 2018. The GDPR regulates the processing of personal data and protects the rights and privacy of all living individuals (including children), for example by giving all individuals who are the subject of personal data a general right of access to the personal data which relates to them. Individuals can exercise the right to gain access to their information by means of a ‘subject access request’. Personal data is information relating to an individual and may be in hard or soft copy (paper/manual files; electronic records; photographs; CCTV images) and may include facts or opinions about a person.

Responsibilities under the GDPR

Netcare Europe Limited is the ‘data controller’ under the terms of the legislation – this means it is ultimately responsible for deciding the “purposes and means of the processing of personal data”. It must be ensured that all data is processed in compliance with principles of lawfulness, fairness, transparency, data minimisation, accuracy, storage limitation, integrity, and confidentiality.

The Company may appoint a Data Protection Officer (DPO) if the handling of data grows to a large scale or involves processing of sensitive data on a large scale. This will be a competent person with expertise in data protection or a relevant area, who is available to address any concerns regarding the data held and how it is processed, held and used.

Types of data held

Netcare Europe Limited may collect and process personal data, including but not limited to:

Information you provide to us:

• Name, email address, postal address, phone number, and other contact details including that of personnel.

• Payment information when purchasing products or services.

• Insurance documents and Health & Safety policies.

• Details of correspondence if you contact us.

• Accreditations and training records of personnel.

Information from Third Parties:

• Data from social media platforms if you interact with our accounts.

• Information from business partners or other third-party sources.

To comply with legal obligations, including the obligations imposed on it by the General Data Protection Regulation (GDPR) Netcare Europe Limited must ensure that all this information about individuals is collected and used fairly, stored safely and securely, and not disclosed to any third party unlawfully.

Compliance

This policy applies to all staff and suppliers. Any breach of this policy or of the Regulation itself will be documented and considered an offence, and the Company’s disciplinary procedures will be invoked.

All individuals working within Netcare Europe Limited and who have access to personal information, will be expected to comply with this policy. It is expected that personnel who are responsible for dealing with external bodies will ensure that such bodies are made aware of and understand their responsibilities, and where necessary sign a contract which will include an agreement to abide by this policy.

The ICO Code of Practice on GDPR for gives further detailed guidance about how to handle and process data in a way which complies with data protection law.

Data Protection Principles

The legislation places a responsibility on every data controller to process any personal data in accordance with the seven key principles.

More detailed guidance on how to comply with these principles can be found in the ICO Code of Practice.

In order to comply with its obligations, Netcare Europe Limited undertakes the following to adhere to the seven principles:

1) Lawfulness, fairness and transparency.

Netcare Europe Limited will make all reasonable efforts to ensure that individuals who are the focus of the personal data (data subjects) are informed of the identity of the data controller, the purposes of the processing, any disclosures to third parties that are envisaged; given an indication of the period for which the data will be kept, and any other information which may be relevant.

2) Purpose limitation.

Netcare Europe Limited will ensure that the specific and lawful reason for which it collected the data originally is the only reason for which it processes the data, unless the individual is informed and consents to any additional processing before it takes place. The data will not be further handled in a manner incompatible with this purpose.

3) Data Minimisation.

Netcare Europe Limited will not seek to collect any personal data which is not strictly necessary for the purpose for which it was obtained. Forms for collecting data will always be drafted with this mind. If any irrelevant data are given by individuals, said data will be destroyed immediately.

4) Data Accuracy.

Netcare Europe Limited will review and update all data on a regular basis. It is the responsibility of the individuals giving their personal data to ensure that this is accurate, and each individual should notify the Company if, for example, a change in circumstances mean that the data needs to be updated. It is the responsibility of the Company to ensure that any notification regarding the change is noted and acted on.

5) Storage limitation.

Netcare Europe Limited undertakes not to retain personal data for longer than is necessary to ensure compliance with the legislation, and any other statutory requirements. A regular review of the information held will be completed to ensure this.

Netcare Europe Limited will dispose of any personal data in a way that protects the rights and privacy of the individual concerned, such as via secure electronic deletion, and shredding and disposal of hard copy files as confidential waste. A log will be kept of the records destroyed.

Personal data will be stored in accordance with the rights of the data subject under the legislation. Individuals have various rights under the legislation including a right to:

• Be told the nature of the information the Company holds and any parties to whom this may be disclosed.

• Prevent processing likely to cause damage or distress.

• Prevent processing for purposes of direct marketing.

• Be informed about the mechanics of any automated decision-making process that will significantly affect them.

Netcare Europe Limited will only process personal data in accordance with individuals’ rights.

6) Data integrity and confidentiality

Netcare Europe Limited will ensure that all personal data is accessible only to those who have a valid reason for using it.

Appropriate technical and organisational measures are in place against unauthorised or unlawful processing of personal data, and against accidental loss or destruction of data.

Netcare Europe Limited will have in place appropriate security measures such as:

• Keeping all personal data in a lockable cabinet with limited, key-controlled access.

• Password protecting personal data held electronically.

• Archiving personal data which are then kept securely (lockable cabinet).

• Positioning any PCs or terminals, CCTV camera screens etc. that show personal data so that they are not visible except to authorised staff.

• Ensuring that PC screens are not left unattended without a password protected screen-saver being used.

In addition, Netcare Europe Limited will put in place appropriate measures for the deletion of personal data - manual records will be shredded or disposed of as ‘confidential waste’ and contract terms will be put in place with any third parties undertaking this work as appropriate. Hard drives of redundant PCs will be wiped clean before disposal or if that is not possible, destroyed physically. A log will be kept of the records destroyed.

This policy also applies to staff who process personal data ‘off-site’, e.g. when working at home, and in circumstances additional care must be taken regarding the security of the data.

7) Accountability

Netcare Europe Limited will ensure that no personal data is transferred to a country or territory outside the United Kingdom unless that country or territory ensures adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data. Netcare Europe Limited will not transfer data to such territories without the explicit consent of the individual.

All members of staff are trained and responsible for ensuring that any personal data which they hold is kept securely and not disclosed to any unauthorised third parties.

This also applies to publishing information on the Internet - because transfer of data can include placing data on a website that can be accessed from outside the UK- so Netcare Europe Limited will seek the consent of individuals before placing any personal data (including photographs) on its website.

If the Company collects personal data in any form via its website, it will provide a clear and detailed privacy statement prominently on the website, and wherever else personal data is collected.

Consent as a basis for processing

Although it is not always necessary to gain consent from individuals before processing their data, it is often the best way to ensure that data is collected and processed in an open and transparent manner.

Consent is especially important when Netcare Europe Limited is processing any sensitive data, as defined by the legislation.

Netcare Europe Limited understands consent to mean that the individual has been fully informed of the intended processing and has signified their agreement (e.g. via the enrolment form) whilst being of a sound mind and without having any undue influence exerted upon them. Consent obtained based on misleading information will not be a valid basis for processing. Consent cannot be inferred from the non-response to a communication.

Netcare Europe Limited will review and update this policy as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments to the GDPR, Data Protection and any other relevant legislation.