Denise Nathan Consultancy Ltd: Data Protection Policy
1. What information do we keep, how do we store it in how long do we keep it for?
This consists of the names of clients, their business address, on occasions their home address, mobile telephone numbers and email addresses work and personal. This information is stored on the company’s computer and nowhere else. It is retained until the company elects to destroy it, or alternatively the client asks us to destroy it.
Information taken by the company’s director, Denise Nathan at interview. Denise makes an aide memoir when she interviews clients. This is recorded in manuscript. The notes are kept in a lever arch file at the company’s premises in Cobham. These notes are retained for a maximum of one year or until the end of the process the client is going through whichever is the shorter period. At the end of that period the notes are shredded.
Restrictions on the dissemination of information held
None of this information is copied to or held on other computer devices, tablets or mobile phones.
The company’s computer is password protected. The only persons with access to that password and therefore to the information on the computer are Denise Nathan and any person employed as the company’s secretary from time to time.
The company consists only of Denise Nathan and a secretary. They compile the information referred to at paragraph 1 above. The company engages the services of various consultants all of whom are self-employed, i.e. independent contractors who are not employees of the company. When they see the company’s clients they may also make notes of their interviews with them or take information from them. This information is not retained by the company. The subcontractors also comply with the policy set out at 1b above in relation to that information.
3. Copyright an confidentiality
Manuscript notes made by Denise Nathan are subject to her copyright and protected by copyright law.
The manuscript notes made by her are strictly confidential. They are not made known to any third person under any circumstances without the express written agreement of the subject of the notes
4. Subject access requests
Any subject access request for manuscript notes kept by Denise Nathan will be dealt with within 28 days of receipt of such request providing it is in writing.
5. This policy is shown on the Denise Nathan consultancy website.
6. This information is also provided to new clients. In entering into an agreement with the Denise Nathan Consultancy Ltd the client agrees to the retention of the information set out at paragraph 1 above and for the purposes set out at that paragraph.