GDPR Compliance

Introduction

This policy sets out how Care Agency Management Application (“C.A.M.A”) will process data and the rights of data subjects under data protection law, including the EU the General Data Protection Regulation (GDPR).

Data processing

C.A.M.A collects and processes personal data received directly from data subjects when such data subjects request information on the company’s services or interact with the company in any other way.

C.A.M.A only processes personal data for specific purposes with a lawful basis as notified to the data subject, or for other purposes permitted by data protection legislation (including the GDPR). The purposes for which we process personal data will be communicated to data subjects at the time that their personal data is collected, where it is collected directly from them, or as soon as possible, and within one calendar month, after collection where it is obtained from a third-party.

Consent: Informed consent shall be obtained when personal data is collected, and individuals will be given the opportunity to opt-out of marketing communications from C.A.M.A. Under this policy, C.A.M.A and anyone working on our behalf, shall explain the purpose for processing data and how it will be used, and the lawful basis on which it is processed. Any personal data that is collected will be stored securely and confidentially. Information and records relating to clients will be stored securely and only be accessible to authorised personnel.

Accuracy of Data: C.A.M.A shall ensure that all personal data collected and processed is kept accurate and up-to-date. The accuracy of data shall be checked when it is collected. If we become aware of any inaccuracies or find that data is out-of-date, we will take reasonable steps to amend or erase that data, as appropriate and without undue delay.

Timely processing: C.A.M.A shall not keep personal data for any longer than is necessary for the purpose for which it was originally collected and processed. When the data is no longer required, all reasonable steps will be taken to erase it without undue delay.

Secure processing: C.A.M.A shall take appropriate steps to ensure that all personal data collected and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage. Where special categories of personal data are processed, extra measures are taken to ensure that information disclosed relating to individuals is handled appropriately. We will undertake privacy impact assessments in the use of technology and any changes to our processes and procedures in order to ensure the security of personal data.

Accountability: C.A.M.A will keep appropriate records of all personal data collected and processed, which shall include the following information:

• The purposes for which we process the personal data.
• Details of the categories of personal data collected, held, and processed by us and the categories of data subject to which that personal data relates.
• Details (and categories) of any third parties that will receive personal data from the C.A.M.A.
• Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards.
• Details of how long personal data will be retained.
• Details of technical and organisational measures taken by C.A.M.A to ensure the security of personal data.

Privacy policy

The C.A.M.A Privacy Policy is published on our website and incorporates the principles of this data protection policy and addresses our obligations under data protection law applicable in the UK. Our website is hosted by Vultr, see: here

When users visit our website, we will automatically process and record information such as IP address, time and date of visit, users’ computer operating system, and the type of web browser used. This information is used in an anonymised way to make decisions about how to improve our services. Further details are explained in our Privacy Policy and Cookies Policy. We ask for consent for marketing communications when users register for our services and users are able to withdraw their consent at any time via the settings on the website. We do not send unsolicited emails to personal email addresses.

Cookies policy

C.A.M.A uses cookies to enable our systems to recognise a user’s browser or device and to provide our services. Some cookies are sent from third parties, while others are sent by services used to enhance our website. Non-necessary cookies are used on the basis of a user’s consent and may be withdrawn at any time by changing the users’ settings on the website, or by contacting us by email. Details of our cookies are contained in our Cookie Policy available on our website.

Rights of data subjects

Subject Access Requests: A data subject may make a subject access request (SAR) at any time to find out more about the personal data which the Company holds about them. All requests will be logged as soon as received by us. Any release of personal data will be checked to see whether it reveals the identity of a third-party. This information can either be redacted, or the third party will be contacted to consent to the release of the information. Personal data will only be released to the person seeking access to their data, or someone who has written consent from the individual to receive the data.

All subject access requests received must be forwarded to privacy@gazelleweb-tech.com. C.A.M.A does not charge a fee for the handling of normal SARs. We reserve the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

If C.A.M.A decides to refuse a subject access request, we will write to the data subject to explain our reason, within one month of receiving the request.

Rectification of Personal Data: If a data subject informs us that personal data held by C.A.M.A is inaccurate or incomplete, requesting that it be rectified, the personal data in question shall be rectified, and the data subject informed of that rectification, within one month of receipt the data subject’s notice. This can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension.

Erasure of Personal Data: Data subjects may request that C.A.M.A erase the personal data it holds about them in the following circumstances:

• It is no longer necessary for C.A.M.A to hold that personal data with respect to the purpose for which it was originally collected or processed.
• The data subject wishes to withdraw their consent to C.A.M.A holding and processing their personal data.
• The data subject objects to C.A.M.A holding and processing their personal data and there is no overriding legitimate interest to allow the Company to continue doing so.
• The personal data has been processed unlawfully.
• The personal data needs to be erased in order for C.A.M.A to comply with a particular legal obligation.
• Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).
• In the event that any personal data that is to be erased in response to a data subject request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

Restriction of Personal Data Processing: Data subjects may request that C.A.M.A ceases processing the personal data it holds about them. If a data subject makes such a request, we shall retain only the amount of personal data pertaining to that data subject that is necessary to ensure that no further processing of their personal data takes place. In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

Data Portability: C.A.M.A processes personal data using automated means. Where data subjects have given their consent to C.A.M.A to process their personal data in such a manner or the processing is otherwise required for the performance of a contract between the Company and the data subject, data subjects have the legal right under the Regulation to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers). To facilitate the right of data portability, C.A.M.A may make available all applicable personal data to data subjects in CSV format. Where possible and if requested by a data subject, personal data shall be sent securely and directly to another data controller. All requests for copies of personal data shall be processed and delivered within one month of the data subject’s request. This may be extended by up to two months in the case of complex requests or if the processing is complex or there have been numerous such requests. In such cases the data subject shall be informed of the need for the extension.

Objections to Personal Data Processing: Data subjects have the right to object to C.A.M.A processing their personal data. Where a data subject objects to the processing of their personal data based on the legitimate interests of C.A.M.A, we shall cease processing the data immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights and freedoms, or the processing relates to a legal claim. Where a data subject objects to C.A.M.A processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.

Automated Decision-Making In the event that C.A.M.A uses personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on data subjects, data subjects have the right to challenge such decisions under the Regulation, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us. Individuals are able to refer any concerns to us by email. This right does not apply in the following circumstances:

• The decision is necessary for the entry into, or performance of, a contract between the Company and the data subject.
• The decision is authorised by law; or
• The data subject has given their explicit consent.

Profiling: Where C.A.M.A uses personal data for profiling purposes, we will provide clear information explaining its use, significance and the likely consequences. We may utilise appropriate mathematical or statistical procedures i.e. algorithms, which shall be the proprietary ownership of C.A.M.A. Technical and organisational measures will be taken as necessary to minimise the risk of errors and to enable such errors to be easily corrected. Personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

Data Breach notification

For citizens in the UK and EU, in the event that a personal data breach is likely to result in a high risk to the rights and freedoms of data subjects, all affected data subjects will be informed by Gazelle Web-Tech of the breach directly and without undue delay. Data Breaches will also be notified to the Information Commissioner’s Office (ICO) (or other relevant data protection authority) without delay, and in any event, within 72 hours.

Data retention periods

C.A.M.A will keep records in accordance with the statutory retention periods.

Data storage

Information and records relating to clients are stored securely and only accessible to authorised personnel. Personal data is stored only for as long as it is needed or required by statute and will be disposed of appropriately.
Gazelle Web-Tech take appropriate steps to ensure that all personal and company data is non-recoverable from any computer system previously used, when sold or otherwise passed over to a third-party.
Where special categories of personal data are processed, extra measures will be taken to ensure that information disclosed relating to individuals is handled appropriately.

Transferring personal data

Gazelle Web-Tech may transfer, including making available remotely, personal data to countries outside of the EEA. The transfer shall take place only if one or more of the following applies:

• The transfer is to a country, territory, or one or more specific sectors in that country, that the European Commission has determined ensures an adequate level of protection for personal data.
• The transfer is to a country, or international organisation, which provides appropriate safeguards as approved by the Information Commissioner’s Office; or as permitted by the GDPR.
• The transfer is made with the informed consent of the relevant data subject(s).
• The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject).
• The transfer is necessary for important public interest reasons.
• The transfer is necessary for the conduct of legal claims.
• The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
• The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

Data processors

Third party Data Processors may be used to provide elements of our service. We will ensure that we have contracts in place with our data processors which are legally binding to ensure that personal data is not disclosed to unauthorised parties, that it is held securely and only used on the lawful basis for which it is collected. Data processors are required to keep records of all data processing activities. Data Processors are obliged to assist and cooperate with Data Controllers to fulfil their obligations under the GDPR. Where appropriate third-parties shall be required to sign a non-disclosure agreement.

Marketing

Where personal data held is used for marketing purposes, we will ensure that prior to use, details are checked against any marketing preference databases including, the Telephone Preference Service, the Mail Preference Service, the Email Preference Service, and the Fax Preference Service, in the relevant country. Further details in respect to privacy are explained in our Privacy Policy available on the website.

Record marketing

Gazelle Web-Tech shall maintain appropriate records in order to administer this Data Protection Policy. These will be maintained in an electronic format on the company’s record-keeping system.

Policy review

This Data Protection Policy will be reviewed and monitored regularly to ensure that it is effective, relevant and up-to-date with best practice and data protection law