General Data Protection Policy

Oasis Care and Training is committed to being transparent about how it collects and uses the personal data of its workforce, and to meeting its data protection obligations. This policy sets out our commitment to data protection, and individual rights and obligations in relation to personal data.

This policy applies to the personal data of job applicants, employees, workers, service users, contractors, commissioners, volunteers, interns, apprentices and former employees, referred to as personal data.

Oasis has appointed Julie Weekes as its data protection officer for the purpose of Human Resources data. Her role is to inform and advise the organisation on its data protection obligations. She can be contacted at jweekes@oasiscareandtraining.org.uk.  Questions about this policy, or requests for further information, should be directed to her.

Oasis also appointed an additional person, Adetayo Oke, with responsibility for data protection within the Care department data and he can be contacted at AOke@oasiscareandtraining.org.uk.

Mohamud Ileye was appointed for Finance Department data and he can be contacted at: mileye@oasiscareandtraining.org.uk Questions about data within the care sector or finance, or requests for further information, should be directed to them respectively.

Definitions

"Personal data" is any information that relates to a living individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.

 

"Special categories of personal data" means information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and genetic and biometric data.

 

"Criminal records data" means information about an individual's criminal convictions and offences, and information relating to criminal allegations and proceedings.

Data protection principles

Oasis processes personal data in accordance with the following data protection principles:

  • We process personal data lawfully, fairly and in a transparent manner.

  • We collect personal data only for specified, explicit and legitimate purposes.

  • We will process personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.

  • We will keep accurate personal data and take all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.

  • We will keep personal data only for the period necessary for processing.

  • We will adopt appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage by ensuring our processes are robust and adhered to at all times.

 

We will inform individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons. We will carry out regular assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.

Oasis processes special categories of personal data including criminal records data, bank accounts and transactions to perform obligations or to exercise rights in employment law, this is done in accordance our DBS and recruitment and vetting policy. We also process individual care needs of service users and names contacts of their Next of Kin (NOK). 

Oasis will update personal data promptly if an individual advises that his/her information has changed or is inaccurate. This includes updating DBS records and expiry of EU passports. All processes are in place and individuals must adhere to their responsibilities to advice of any changes.

Personal data gathered during the employment of a worker, contractor, volunteer, apprenticeship or internship is held in the individual's personnel file currently in hard copy but will be transferred to an electronic format in the near future. The periods for which the organisation holds personal data are contained in its privacy notices to individuals.

Oasis keeps a record of its processing activities in respect of personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).

Individual rights

As a data subject, individuals have a number of rights in relation to their personal data.

Subject access requests

Individuals have the right to make a subject access request. If an individual makes a subject access request, we will tell him/her:

  • whether or not his/her data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;

  • to whom his/her data is or may be disclosed, including to recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;

  • for how long his/her personal data is stored (or how that period is decided);

  • his/her rights to rectification or erasure of data, or to restrict or object to processing;

  • his/her right to complain to the Information Commissioner if he/she thinks Oasis has failed to comply with his/her data protection rights; and

  • whether or not we carry out automated decision-making and the logic involved in any such decision-making.

 

Oasis will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically, unless he/she agrees otherwise.

If the individual wants additional copies, the organisation will charge a fee, which will be based on the administrative cost to the organisation of providing the additional copies.

To make a subject access request, the individual should send the request to jweekes@oasiscareandtraining.org.uk or use the form for making a subject access request. In some cases, we may need to ask for proof of identification before the request can be processed. The organisation will inform the individual if it needs to verify his/her identity and the documents it requires.

Oasis will normally respond to a request within a period of one month from the date it is received. In some cases, such as where we process large amounts of the individual's data, it may respond within three months of the date the request is received. Oasis will write to the individual within one month of receiving the original request to tell him/her if this is the case.

If a subject access request is manifestly unfounded or excessive, Oasis is not obliged to comply with it. Alternatively, we can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which the organisation has already responded. If an individual submits a request that is unfounded or excessive, Oasis will notify him/her that this is the case and whether or not it will respond to it.

Other rights

Individuals have a number of other rights in relation to their personal data. They can require Oasis to:

  • rectify inaccurate data;

  • stop processing or erase data that is no longer necessary for the purposes of processing;

  • stop processing or erase data if the individual's interests override Oasis legitimate grounds for processing data (where Oasis relies on its legitimate interests as a reason for processing data);

  • stop processing or erase data if processing is unlawful; and

  • stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual's interests override Oasis legitimate grounds for processing data.

 

To ask the organisation to take any of these steps, the individual should send the request to jweekes@oasiscareandtraining.org.uk

Data security

Oasis takes the security of personal data seriously. We have internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.

Impact assessments

Some of the processing that Oasis carries out may result in risks to privacy. Where processing would result in a high risk to individual's rights and freedoms, Oasis will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.

 

Data breaches

If the organisation discovers that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, it will report it to the Information Commissioner within 72 hours of discovery. The organisation will record all data breaches regardless of their effect.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, it will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.

Individual responsibilities

Individuals are responsible for helping the agency to keep their personal data up to date. Individuals should let us know if data provided to Oasis changes, for example if an individual moves house or changes his/her bank details.

Individuals may have access to the personal data of other individuals and of our customers and clients in the course of their employment, contract, volunteer period, internship or apprenticeship. Where this is the case, the organisation relies on individuals to help meet its data protection obligations to staff and to customers and clients.

 

Individuals who have access to personal data are required:

  • to access only data that they have authority to access and only for authorised purposes;

  • not to disclose data except to individuals (whether inside or outside the organisation) who have appropriate authorisation;

  • to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);

  • not to remove personal data, or devices containing or that can be used to access personal data, from the organisation's premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device;

  • not to store personal data on local drives or on personal devices that are used for work purposes; and

  • to report data breaches of which they become aware to Julie Weekes immediately.

 

Further details about Oasis security procedures can be found in its data security policy.

Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under Oasis disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.

Training

Oasis will provide training to all individuals about their data protection responsibilities as part of the induction process and at regular intervals thereafter.

Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.

 

Law relating to this document

Leading statutory authority

General Data Protection Regulation (2016/679 EU)

Data Protection Bill

 

The General Data Protection Regulation (GDPR) requires employers to:

  • process personal data lawfully, fairly and in a transparent manner;

  • collect data for specified and legitimate purposes and not process data in a manner that is incompatible with those purposes;

  • collect data that is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;

  • ensure that data is accurate and kept up to date, and take every reasonable step to rectify or erase data that is inaccurate without delay;

  • keep data only for the period necessary for the purposes of processing;

  • ensure that appropriate robust processes and security is in place to protect data against unauthorised or unlawful processing, accidental loss, destruction or damage;

  • process data in accordance with the rights of data subjects; and

  • transfer data outside the European Economic Area (EEA) only if there is an adequate level of protection for the rights and freedoms of data subjects.

CALL US:

Head Office

0207 639 6192

 

Central London Office

0207 358 8938

 

West London Office

0207 358 8936

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