Data Protection Policy

MHB Academy needs to gather and use certain information about individuals, including customers, suppliers, business contacts, employees, and other relevant parties. This policy describes how personal data must be collected, handled, and stored to meet the company’s data protection standards and comply with the law.

Purpose:

This data protection policy ensures MHB Academy:

• Complies with data protection law and follows good practices.
• Protects the rights of staff, customers, and partners.
• Is transparent about how it stores and processes individuals’ data.
• Protects itself from the risks of a data breach.

Data Protection:

While data protection guidelines are still being drafted by the government, MHB Academy endeavors to ensure data is not misused. Our philosophy is governed by seven important principles:

• Processed fairly and lawfully
• Obtained only for specific, lawful purposes
• Adequate, relevant, and not excessive
• Accurate and kept up to date
• Not held for any longer than necessary
• Processed in accordance with the rights of data subjects
• Protected in appropriate ways

Policy Scope:

This policy applies to all staff, branches, contractors, volunteers, suppliers, and other individuals working on behalf of MHB Academy. It covers all data that the company holds relating to identifiable individuals, including names, postal addresses, email addresses, telephone numbers, and any other information relating to individuals.

Data Protection Risks:

This policy helps protect MHB Academy from various data security risks, including:

• Breaches of confidentiality, such as information being given out inappropriately.
• Failing to offer choice, where individuals should be free to express objections about how their data is used.
• Reputational damage, such as suffering consequences if hackers gain access to sensitive data.

Responsibilities:

Everyone who works for or with MHB Academy has some responsibility for ensuring data is collected, stored, and handled appropriately. Each team that handles personal data must ensure it is processed in line with this policy and data protection principles.

However, key individuals have specific responsibilities:

• The head of the academy, Mr. Gaurav Bansal, is ultimately responsible for ensuring that MHB Academy meets its legal obligations.
• The moderator, Ms. Gail Fernandes, is responsible for arranging data protection training, handling data protection questions, dealing with requests from individuals to see their data, and checking contracts with third parties handling sensitive data.
• The IT Manager, Mr. Saurabh, is responsible for ensuring all data storage systems meet security standards, performing regular security checks, and evaluating third-party services.
• The Marketing Manager, Ms. Gail Fernandes, is responsible for approving data protection statements, addressing queries from journalists or media outlets, and ensuring marketing initiatives comply with data protection principles.

General Staff Guidelines:

The only people able to access data covered by this policy should be those who need it for their work. Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers. Mr. Saurabh will provide training to all employees to help them understand their responsibilities when handling data. Employees should keep all data secure, by taking sensible precautions and following the guidelines below.

• Strong passwords must be used and they should never be shared.
• Personal data should not be disclosed to unauthorized people, either within the company or externally.
• Data should be regularly reviewed and updated if found to be out of date. If no longer required, it should be deleted and disposed of.
• Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data Storage:

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

• When data is stored on paper, it should be kept in a secure place where unauthorized people cannot see it.
• When not required, paper or files should be kept in a locked drawer or filing cabinet.
• Data printouts should be shredded and disposed of securely when no longer required.
• Data should be protected by strong passwords that are changed regularly and never shared between employees.
• If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
• Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
• Servers containing personal data should be sited in a secure location, away from general office space.
• Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
• Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
• All servers and computers containing data should be protected by approved security software and a firewall.

Data Use:

Personal data is of no value to MHB Academy unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption, or theft.

• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
• Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
• Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorized external contacts.
• Personal data should never be transferred outside the intended jurisdiction.
• Employees should not save copies of personal data to their own computers.
• Always access and update the central copy of any data.

Data Accuracy:

The common sense requires MHB Academy to take reasonable steps to ensure data is kept accurate and up to date. The more important it is that the personal data is accurate, the greater the effort MHB Academy should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible. Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.

Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call. MHB Academy will make it easy for data subjects to update the information MHB Academy holds about them. They may get in touch with the current point of contact in the company, and the employee will do the needful.

Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database. It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject Access Requests:

All individuals who are the subject of personal data held by MHB Academy are entitled to:

• Ask what information the company holds about them and why.
• Ask how to gain access to it.
• Be informed how to keep it up to date.
• Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request. Subject access requests from individuals should be made by email, addressed to the data controller at info@myhealtybuddy.co. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged INR 500 per subject access request. The data controller will aim to provide the relevant data within 14 days. The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons:

In certain circumstances, we may need to allow personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, MHB Academy will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Providing information:

MHB Academy aims to ensure that individuals are aware that their data is being processed, and that they understand:

• How the data is being used
• How to exercise their rights

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.