Equine Performance Therapy or the Company takes its obligations with respect to the personal data of clients very seriously. As a small company with limited resources and no website at present, this notice is in relation to the personal data that we collect about you and your horses for identification purposes only and to facilitate the optimum treatment of your horses and communication with you, the client. We ask that you read the following Policy which fulfils our legal requirements under GDPR and contact us if you have any concerns or questions about our privacy practices.
- Data protection principles
The Company is committed to processing data in accordance with its responsibilities under GDPR.
Article 5 of the GDPR requires that personal data shall be:
processed lawfully, fairly and in a transparent manner in relation to individuals;
collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes, in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
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;
kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes, in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.’
2. General provisions
This Policy applies to all personal data processed by the Company. This includes all of the information that we collect on the EPT Initial Consultation Form and the EPT Follow-Up Consultation Forms and any other information that we may collect in any interim correspondence with you e.g. email communication.
The Responsible Person shall take responsibility for the Company’s ongoing compliance with this Policy.
This Policy shall be reviewed at least annually.
The Company shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems.
The Register of Systems shall be reviewed at least annually.
Individuals have the right to access their personal data and any such requests made to the Company shall be dealt with in a timely manner. If a client wishes to access the personal data held by the Company, a written request should be made to the Responsible Person either by email at [email protected] or to the Registered Office address set out in the footer of this Policy.
4. Lawful purposes
All data processed by the Company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
We primarily rely on your consent to enable us to process your personal data, which you give before the initial consultation involving your horse. However, we should point out that it is your right, under GDPR, to withdraw that consent at any time or to otherwise manage your consent by contacting us either by email at [email protected] or to the Registered Office address set out in the footer of this Policy. Please be aware that for your own protection, we may request additional identify verification before being able to comply with any personal data access requests.
We may use your data for matters including, but not limited to, personalisation of content, account set up and administration, delivering marketing or events communication or carrying out polls or surveys.
The Company shall note the appropriate lawful basis in the Register of Systems.
We will not share your personal data with any other organisation unless we either ask for your consent before doing so, such consent not to be unreasonably withheld or delayed, or if we are obligated to do so in order to comply with governmental organisation requests e.g. ICO or HMRC or are ordered to do so by a Court of Law or other regulatory body or to prevent fraud.
5. Data minimisation
The Company shall ensure that the personal data which are processed are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
The Company shall take reasonable steps to ensure personal data are
Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
We respect the right of clients to access and control your personal data and so we welcome any requests to such access by emailing [email protected] or writing to the Registered Office address at the footer of this Policy. We agree to deal with all such requests on a timely basis given the context that we are a very small company with limited resources available.
We further acknowledge that clients have a right to the correction or deletion of such personal data held by us, and we agree to comply with such requests on a timely basis although we should point out that we may be unable to comply fully with a request should such request involve the exposure of personal data about another person, or if we are asked to delete data that we may be required to keep by law. In such circumstances we will, of course, fully explain the reasons why we cannot comply.
7. Archiving / removal
To ensure that personal data is kept for no longer than necessary, the Company shall keep personal data for as long as is necessary in order to comply with requirements of insurance policies held or otherwise in order to comply with contractual obligations, requirements of any regulatory bodies to which we subscribe and/or any laws to which we may be subject.
We will review the need to keep personal data on an annual basis.
The Company shall take reasonable steps to ensure that personal data is stored securely using modern software that is kept-up-to-date.
Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
When personal data is deleted this will be done safely such that the data is as irrecoverable as modern software systems permit.
Appropriate back-up and disaster recovery solutions shall be in place.
Any written records shall be kept securely in a lockable, fireproof cabinet.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO.
We take our obligations towards the security of your personal data very seriously. However, should we fail to meet your expectations in such regard, we ask that in the first instance you allow us the opportunity to deal with any dissatisfaction you may have by emailing us at [email protected] or writing to the Registered Office address at the footer of this Policy. Should we fail to deal with your complaint satisfactorily then you may wish to contact the Information Commissioner’s office at www.ico.org.uk.