1. Confidentiality Notice

This document and the information contained therein is the property of Flow Living Medi-Care Services Ltd.

This document contains information that is confidential and privileged. It must not be copied, revealed, transferred and or transmitted either as a hard copy or by electronic or digital format without the explicit consent in writing from Flow Living Medi-Care Services Ltd.

DATA PROTECTION POLICY

Policy Statement 

Policy Aims 

• To ensure that Flow Living Med- Care Services Ltd apply appropriate measures to comply with the eight principles of the Data Protection Act 2018 to meet our legal requirements, information is kept secure, accurate and up to date.
•  

To inform staff on how data is protected within Flow Living       Medi-Care Services Ltd, and what their responsibilities are pertaining to the Data Protection of our clients and service users. 

Flow Living Medi-Care Services Ltd collect and use certain type of information about employees, service users, and individuals who use  Flow Living Medi- Care Services Ltd services. The information collected is used in compliance with the principles of the data protection act and safeguarded to ensure it complies with the Data   Protection Act 2018. 

Personal Information is any data relating to a living individual, and under the Data Protection Act 2018 all Personal Information: 

• Must be processed fairly and lawfully; 
• Must be obtained for one or more specific and lawful purposes and only processed in a manner compatible with them; 
• Must be adequate, relevant and not excessive for the purposes defined;
• Must be accurate and where necessary kept up to date; 
• Shall not be kept for longer than is necessary; 
• Must be processed in accordance with the data subject’s rights; 
• Must be kept secure; 
• Must not be transferred outside the European economic area unless there is adequate protection for the rights of data subjects. 

Data Controller 

Flow Living Medi- Care Services Ltd is the Data Controller under the Act, which means that it determines what purposes held personal information will be used for. It is also responsible for notifying the Information Commissioner of the data it holds or is likely to hold, and the general purposes that this data will be used for. 

Disclosure 

Flow Living Medi- Care Services Ltd may share data with other agencies such as the local authority. 

The Individual/Service User will be made aware the circumstances, how and with whom   their information will be shared. There are circumstances where the law allows Flow Living Medi-Care Living Services Ltd to disclose data (including sensitive data) without the data subject’s   consent.  

These are: 

a) Carrying out a legal duty or as authorised by the Secretary of State

b) Protecting vital interests of an Individual/Service User or other person

c) The Individual/Service User has already made the information public

d) Conducting any legal proceedings, obtaining legal advice or defending any legal rights 

e) Monitoring for equal opportunities purposes –i.e., race, disability or religion f) Providing a confidential service where the Individual/Service User’s consent cannot be obtained or where it is reasonable to proceed without consent: e.g., where we would wish to avoid forcing stressed or ill Individuals/Service Users to provide consent signatures. 

Flow   Living Medi-Care Services Ltd regards the lawful and correct treatment of personal information   as very important to successful working, and to maintaining the confidence of those with   whom we work with.  

Flow   Living   Medi-Care Services Ltd is duty bound to ensure that personal information is treated lawfully   and correctly. 

Flow Living Medi- Care Services Ltd will adhere to the Principles of Data Protection as detailed in the Data Protection Act 2018. 

Our Commitment 

Flow Living Medi- Care Services Ltd will: 

• Observe fully conditions regarding the fair collection and use of information 
• Meet its legal obligations to specify the purposes for which information is used 
• Collect and process appropriate information, and only to the extent that it is needed to fulfil its operational needs or to comply with any legal requirements 
• Ensure the quality of information used 
• Ensure that the rights of people about whom 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 
• The right to prevent processing in certain circumstances and 
• The right to correct, rectify, block or erase information which is regarded as wrong information
• Take appropriate technical and organizational security measures to safeguard personal information
• Ensure that personal information is not transferred abroad without suitable safeguards 
• Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information 
• Set out clear procedures for responding to requests for information 

Data collection 

Informed consent is when an individual/service user clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data and then gives their consent. 

Flow Living Medi – Care Services Ltd will ensure that data explicit consent is sought before data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form. When collecting data, Flow Living Medi- Care Services Ltd will ensure that the Individual/Service User: 

a) Clearly understands why the information is needed 

b) Understands what it will be used for and what the consequences are should the Individual/Service User decide not to give consent to processing 

c) As far as reasonably possible, grants explicit consent, either written or verbal for data to be processed 

d) Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress 

e) Has received sufficient information on why their data is needed and how it will be used.

Key Question: How will data be stored securely? 

Information and records relating to service users will be stored securely and will   only be accessible to authorised staff. 

Information will be stored for only as long as it is needed or required statute and   will be disposed of appropriately. 

It is Flow Living Medi- Care Services Ltd responsibility to ensure all personal and company   data is non-recoverable from any computer system previously used within the   organisation, which has been passed on/sold to a third party. 

Data Access and Accuracy 

All Individuals/Service Users have the right to access the information Flow Living Medi-Care Services Ltd   holds about them.

Flow Living Medi- Care Services Ltd will also take reasonable steps ensure that this   information is kept up to date by asking data subjects whether there have been any   changes. 

Flow Living Medi- Care Services Ltd ensures that: 

1. It has a Data Protection Officer with responsibility for ensuring compliance with Data Protection 
2. Everyone processing personal information understands that they are responsible for following good data protection practice 
3. Everyone processing personal information is appropriately trained
4. Everyone processing personal information is appropriately supervised 
5. Anybody wanting to make enquiries about handling personal information knows what to do 
6. It deals promptly and courteously with any enquiries about handling personal information
7. It describes clearly how it handles personal information 
8. It will regularly review and audit the ways it holds, manage and use personal information 
9. It regularly assesses and evaluates its methods and performance in relation to handling personal information 
10. All staff are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them 
11. This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 2018. 

Monitoring and Review 

The Managing Director will check this policy is being implemented according the terms set out  and they will review it at   least once a year. We will make improvements to the policy wherever we can.

Key Points to Take Away  

• Personal information will be collected and dealt with appropriately whether is collected on paper, stored in a computer database, or recorded on other material. 
• Information and records relating to service users will be stored securely and will only be accessible to authorized staff. 
• All Individuals/Service Users have the right to access the information Flow Living Medi- Care Services Ltd holds about them.