Table of Contents
- 1-Purpose of Data Protection Policy. 2
- 2-Justification of the Data Protection Policy. 2
- 3-Definition of Data. 2
- 4-Personal data means. 3
- 5-Processing means. 3
- 6-Controller means. 3
- 7-Personal data may include: 3
- 8-Rights of the Individual 4
- 9-Lawfulness of Processing. 5
- 10-Consent. 5
- 11-Performance of a Contract. 5
- 12-Legal Obligation. 5
- 13-Vital Interests of the Data Subject. 5
- 14-Task Carried Out in the Public Interest. 6
- 15-Legitimate Interests. 6
- 16-Privacy by Design. 6
- 17-Contracts Involving the Processing of Personal Data. 6
- 18-International Transfers of Personal Data. 6
- 19-Procedures for staff. 6
- 20-Data Protection Officer. 7
- 21-Breach Notification. 7
- 22-Addressing Compliance to the GDPR. 7
A Data Protection Policy is a way to ensure that everyone working for our organization is on the same page when it comes to complying with laws such as the GDPR. The security and management of data is important to ensure that we can function effectively and successfully for the benefit of our members and the community and voluntary sector.
In doing so, it is essential that people’s privacy is protected through the lawful and appropriate use and handling of their personal information.
The use of all personal data by Regeneration Biology LLC, LTD is governed by:
- The General Data Protection Regulation (GDPR)
- The Data Protection Act 2018 (DPA)
- The Privacy and Electronic Communications Regulations (PECR)
The Privacy and Data Protection Policy is to protect the personal data of those various stakeholders connected to the organization.
In its everyday business operations, Regeneration Biology LLC, LTD makes use of a variety of data about identifiable individuals (‘natural persons’), including data about:
- Users of its websites
- Personal Information
- Other relevant stakeholders
- Current, past, and prospective external visitors
- Current, past, and prospective Members and Associates
In collecting and using this data, the organization is subject to a variety of legislation controlling how such activities may be carried out and the safeguards that must be put in place to protect it. The purpose of this policy is to set out the relevant legislation and to describe the steps Regeneration Biology LLC, LTD is taking to ensure that it complies with it.
This control applies to all systems, people, and processes that constitute the organization’s information systems, including board members, directors, employees, suppliers, and other third parties who have access to the Regeneration Biology LLC, LTD systems.
Compliance with this policy provides assurance for both the organization and individuals that personal data processed by the Regeneration Biology LLC, LTD is handled legally, effectively, and efficiently, with ethical best practice at the root of decision making, in order to protect the privacy and confidentiality of our members and guests and those with whom we do business.
To avoid potential misunderstandings among staff members, we are including a definitions section to define the different terms that are used throughout the document. This will help to ensure that all employees truly understand the directives contained within the DPP.
The most fundamental definitions with respect to this policy are as follows:
Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or
to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Any operation or set of operations that are performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
There are a number of fundamental principles upon which the GDPR is based. These are as follows:
Personal data shall be:
- Processed lawfully, fairly, and in a transparent manner in relation to the data subject (lawfulness, fairness, and transparency)
- Collected for specified, explicit, and legitimate purposes (purpose limitation)
- Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed (data minimization)
- Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (accuracy)
- kept for no longer than necessary (‘retention’).
- Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures (integrity and confidentiality).
Regeneration Biology LLC, LTD will ensure that it complies with all of these aforementioned principles. We are committed to upholding the data protection principles. All personal data under our control must be processed in accordance with these principles.
Please note under GDPR and other global privacy initiatives the personal information (name, business email, etc.,) of our customers may be deemed Personal Data and as such please ensure that personal information transmitted via the marketplace is not used improperly.
- Identification and Characteristics (e.g., names, identification numbers, SSN, SIN, NI etc., gender, age, nationality, languages spoken)
- Personal contact details (private home – residence address, telephone number and email address)
- Business contact details, over and above normal business contact information (business address, telephone number, mail address)
- Family (facts about family members)
- Transactions and purchases (specific or historic transaction purchase details linked to specific individuals)
- Compensation/remuneration and related financial matters (pay and other financial benefits)
- Personal financial information (personal financial accounts and credit) Benefits (health benefits, insurance, stock options etc.)
- Employment related (general employment details such as job description, CV, work history etc.)
- Certificates and licenses (driver license, professional certification etc.)
- Health (current and past physical and mental health)
- Labor relations (union, works councils, another employee representative officer, member of committee etc.)
- Racial or ethnic origin (race, ethnic group, creed)
- Political opinions (political party affiliation, voting history etc.)
- Religious beliefs (religion, membership in particular groups etc.)
- Criminal history (charges, trials, public records, criminal history etc.)
- Sexuality (sexual preferences or lifestyle)
- Biometric (physical characteristics e.g., fingerprints, iris scan)
- Genetic (genetic characteristics – DNA and related analysis)
Under data protection laws, data subjects have certain rights:
- Right to be informed. The right to be told how their personal data is used in clear and transparent language.
- Right of access. The right to know and have access to the personal data we hold about them.
- Right to data portability. The right to receive their data in a common and machine-readable electronic format.
- Right to be forgotten. The right to have their personal data erased.
- Right to rectification. The right to have their personal data corrected where it is inaccurate or incomplete.
- Right to object. The right to complain and to object to processing.
- Right to purpose limitation. The right to limit the extent of the processing of their personal data.
- Rights related to automated decision-making and profiling. The right not to be subject to decisions without human involvement.
Each of these rights are supported by appropriate procedures within Regeneration Biology LLC, LTD that allow the required action to be taken within the timescales stated in the GDPR.
These timescales are shown in Table 1.
|Data Subject Request||Timescale|
|The right to be informed||When data is collected (if supplied by data subject) or within one month (if not supplied by data subject)|
|The right of access||One month|
|The right to rectification||One month|
|The right to erasure||Without undue delay|
|The right to restrict processing||Without undue delay|
|The right to data portability||One month|
|The right to object||On receipt of an objection|
|Rights in relation to automated decision-making and profiling.||Not specified|
There are six alternative ways in which the lawfulness of a specific case of processing of personal data may be established under the GDPR. It is the Regeneration Biology LLC, LTD policy to identify the appropriate basis for processing and to document it, in accordance with the Regulation. The options are described in brief in the following sections.
Unless it is necessary for a reason allowable in the GDPR, Regeneration Biology LLC, LTD will always obtain explicit consent from a data subject to collect and process their data. In the case of children below the age of 16 (a lower age may be allowable in specific EU member states) parental consent will be obtained. Transparent information about our usage of their personal data will be provided to data subjects at the time that consent is obtained and their rights with regard to their data explained, such as the right to withdraw consent. This information will be provided in an accessible form, written in clear language, and free of charge.
If the personal data are not obtained directly from the data subject, then this information will be provided to the data subject within a reasonable period after the data are obtained and definitely within one month.
Where the personal data collected and processed are required to fulfill a contract with the data subject, explicit consent is not required. This will often be the case where the contract cannot be completed without the personal data in question e.g., a delivery cannot be made without an address to deliver to.
If personal data is required to be collected and processed in order to comply with the law, then explicit consent is not required. This may be the case for some data related to employment and taxation for example, and for many areas addressed by the public sector.
In a case where the personal data are required to protect the vital interests of the data subject or of another natural person, then this may be used as the lawful basis of the processing. The Regeneration Biology LLC, LTD will retain reasonable, documented evidence that this is the case, whenever this reason is used as the lawful basis of the processing of personal data. As an example, this may be used in aspects of social care, particularly in the public sector.
Where the Regeneration Biology LLC, LTD needs to perform a task that it believes is in the public interest or as part of an official duty then the data subject’s consent will not be requested. The assessment of the public interest or official duty will be documented and made available as evidence where required.
If the processing of specific personal data is in the legitimate interests of the Regeneration Biology LLC, LTD and is judged not to affect the rights and freedoms of the data subject in a significant way, then this may be defined as the lawful reason for the processing. Again, the reasoning behind this view will be documented.
Regeneration Biology LLC, LTD has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect or process personal data will be subject to due consideration of privacy issues, including the completion of one or more data protection impact assessments.
The data protection impact assessment will include:
- Consideration of how personal data will be processed and for what purposes
- Assessment of whether the proposed processing of personal data is both necessary and proportionate to the purpose(s)
- Assessment of the risks to individuals in processing the personal data
- What controls are necessary to address the identified risks and demonstrate compliance with legislation
Regeneration Biology LLC, LTD will ensure that all relationships it enters into that involve the processing of personal data are subject to a documented contract that includes the specific information and terms required by the GDPR.
Transfers of personal data outside of the country will be carefully reviewed prior to the transfer taking place to ensure that they fall within the limits imposed by the GDPR. This depends partly on the Commission’s judgment as to the adequacy of the safeguards for personal data applicable in the receiving country and this may change over time.
Intra-group international data transfers will be subject to legally binding agreements referred to as Binding Corporate Rules (BCR) which provide enforceable rights for data subjects.
All members of staff must comply with these procedures for processing or transmitting personal data. In addition, staff should be aware of and adhere to policies in relation to cyber security and the use of personal data.
- Always treat people’s personal information with integrity and confidentiality. Don’t hand out personal details just because someone asks you to.
- Where personal data exists as a hard copy, it should be stored in a locked box, drawer or cabinet, and not left where anyone could access it
- Staff are issued with encrypted USB devices for the secure transfer of personal data or sensitive information. No other removable media devices should be used to transfer these types of information without permission from the Systems Administrator or Head of Information Management.
- The loss or theft of any device should be reported as soon as possible to the Systems Administrator or Head of Information Management.
- Take care when connecting to public wi-fi connections, as these can expose your connection to interception. If you’re not sure if a connection is secure, do not connect to it.
- If you are thinking of sending marketing to individuals, consult with the concerned officer first, as there are certain laws that apply to electronic direct marketing. This could include anything that promotes the aims or purpose of Regeneration Biology LLC, LTD including promoting an event or seeking engagement.
- Take care to email the intended recipient (especially where email address autocompletes is turned on). Use the ‘bcc’ field for emailing several people where using ‘to’ or ’cc’ is not needed.
- These procedures and policies also apply to the use of remote access to Regeneration Biology LLC, LTD cloud systems. If you are using your own device to access personal data on Office365 (e.g., Outlook or Dynamics CRM), ensure that your device has a firewall and is password protected.
A defined role of Data Protection Officer (DPO) is required under the GDPR if an organization is a public authority, if it performs large-scale monitoring or if it processes particularly sensitive types of data on a large scale. The DPO is required to have an appropriate level of knowledge and can either be an in-house resource or outsourced to an appropriate service provider.
Based on these criteria, Regeneration Biology LLC, LTD does not require a Data Protection Officer to be appointed.
It is Regeneration Biology LLC, LTD policy to be fair and proportionate when considering the actions to be taken to inform affected parties regarding breaches of personal data. In line with the GDPR, where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant supervisory authority will be informed within 72 hours. This will be managed in accordance with our Information Security Incident Response Procedure which sets out the overall process of handling information security incidents.
Under the GDPR the relevant DPA has the authority to impose a range of fines of up to four percent of annual worldwide turnover or twenty million dollars, whichever is the higher, for infringements of the regulations.
The following actions are undertaken to ensure that the Regeneration Biology LLC, LTD complies at all times with the accountability principle of the GDPR:
- The legal basis for processing personal data is clear and unambiguous
- All staff involved in handling personal data understand their responsibilities for following good data protection practice
- Training in data protection has been provided to all staff
- Rules regarding consent are followed
- Routes are available to data subjects wishing to exercise their rights regarding personal data and such inquiries are handled effectively
- Regular reviews of procedures involving personal data are carried out
- Privacy by design is adopted for all new or changed systems and processes
- The following documentation of processing activities is recorded:
- Organization name and relevant details
- Purposes of the personal data processing
- Categories of individuals and personal data processed o Categories of personal data recipients
- Agreements and mechanisms for transfers of personal data to non-EU countries including details of controls in place
- Personal data retention schedules
- Relevant technical and organizational controls in place
These actions are reviewed on a regular basis as part of the management process concerned with data protection. Individuals involved in corrupt activity may be fined or sentenced to imprisonment. Every member of staff has a responsibility to adhere to the Data Protection Principles outlined in the GDPR, and to this Data Protection Policy.
If you have a question about this Data Protection Policy or an area of concern about data protection matters, please contact our member of the Information Team.