Privacy Policy

Privacy Policy
Context and overview
Key details

Policy prepared by: The Greenwich Spa trading as Mydetoxdiet
Approved by board / management on: SK 24/05/2018
Policy became operational on: 24/05/2018
Next review date: 24/05/2023

The Greenwich Spa needs to gather and use certain information about

These can include customers, suppliers, business contacts, employees and
other people the organization has a relationship with or may need to

This policy describes how this personal data must be collected, handled
and stored to meet the company’s data protection standards — and to
comply with the law.

Why this policy exists
This data protection policy ensures The Greenwich Spa

Complies with data protection law and follow good practice
Protects the rights of staff, customers and partners
Is open about how it stores and processes individuals’ data
Protects itself from the risks of a data breach
Data protection law
The Data Protection Act 1998 describes how organisations — including The
Greenwich Spa — must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically,
on paper or on other materials.

To comply with the law, personal information must be collected and used
fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles.
These say that personal data must:

Be processed fairly and lawfully
Be obtained only for specific, lawful purposes
Be adequate, relevant and not excessive
Be accurate and kept up to date
Not be held for any longer than necessary
Processed in accordance with the rights of data subjects
Be protected in appropriate ways
Not be transferred outside the European Economic Area (EEA), unless that
country or territory also ensures an adequate level of protection

People, risks and responsibilities
This policy applies to:

The head office of The Greenwich Spa
All branches of The Greenwich Spa
All staff and volunteers of The Greenwich Spa
All contractors, suppliers and other people working on behalf of The
Greenwich Spa
It applies to all data that the company holds relating to identifiable
individuals, even if that information technically falls outside of the
Data Protection Act 1998. This can include:

Names of individuals
Postal addresses
Email addresses
Telephone numbers
…plus any other information relating to individuals
Data protection risks
This policy helps to protect The Greenwich Spa from some very real data
security risks, including:

Breaches of confidentiality. For instance, information being given out
Failing to offer choice. For instance, all individuals should be free to
choose how the company uses data relating to
Reputational damage. For instance, the company could suffer if hackers
successfully gained access to sensitive
Everyone who works for or with The Greenwich Spa has some responsibility
for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and
processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

The board of directors is ultimately responsible for ensuring that The
Greenwich Spa meets its legal
The [data protection officers], Susanne Kollner and Ilona Wesle, are
responsible for:
Keeping the board updated about data protection responsibilities, risks
Reviewing all data protection procedures and related policies, in line
with an agreed
Arranging data protection training and advice for the people covered by
Handling data protection questions from staff and anyone else covered by
Dealing with requests from individuals to see the data The Greenwich Spa
holds about them (also called ‘subject access requests’).
Checking and approving any contracts or agreements with third parties
that may handle the company’s sensitive
The [IT manager], [Luis Nieto], is responsible for:
Ensuring all systems, services and equipment used for storing data meet
acceptable security
Performing regular checks and scans to ensure security hardware and
software is functioning properly.
Evaluating any third-party services the company is considering using to
store or process data. For instance, cloud computing
The [marketing manager], [Susanne Kollner], is responsible for:
Approving any data protection statements attached to communications such
as emails and
Addressing any data protection queries from journalists or media outlets
Where necessary, working with other staff to ensure marketing
initiatives abide by data protection

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
The Greenwich Spa will provide training to all employees to help them
understand their responsibilities when handling
Employees should keep all data secure, by taking sensible precautions
and following the guidelines
In particular, strong passwords must be used and they should never be
Personal data should not be disclosed to unauthorized people, either
within the company or
Data should be regularly reviewed and updated if it is found to be out
of date. If no longer required, it should be deleted and disposed
Employees should request help from their line manager or the data
protection officer if they are unsure about any aspect of data

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
unauthorised people cannot see it.

These guidelines also apply to data that is usually stored
electronically but has been printed out for some reason:

When not required, the paper or files should be kept in a locked drawer
or filing cabinet.
Employees should make sure paper and printouts are not left where
unauthorised people could see them, like on a
Data printouts should be shredded and disposed of securely when no
longer required.
When data is stored electronically, it must be protected from
unauthorised access, accidental deletion and malicious hacking attempts:

Data should be protected by strong passwords that are changed regularly
and never shared between
If data is stored on removable media (like a CD or DVD), these should be
kept locked away securely when not being
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
Data should be backed up frequently. Those backups should be tested
regularly, in line with the company’s standard backup
Data should never be saved directly to laptops or other mobile devices
like tablets or smart
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 The Greenwich Spa 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
Personal data should not be shared informally. In particular, it should
never be sent by email, as this form of communication is not
Data must be encrypted before being transferred electronically. The IT
manager can explain how to send data to authorised external
Personal data should never be transferred outside of the European
Economic Area.
Employees should not save copies of personal data to their own
computers. Always access and update the central copy of any

Data accuracy
The law requires The Greenwich Spa 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 The Greenwich Spa 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

Data will be held in as few places as necessary. Staff should not create
any unnecessary additional data
Staff should take every opportunity to ensure data is updated. For
instance, by confirming a customer’s details when they
The Greenwich Spa will make it easy for data subjects to update the
information The Greenwich Spa holds about them. For instance, via the
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
It is the marketing manager’s responsibility to ensure marketing
databases are checked against industry suppression files every six

Subject access requests
All individuals who are the subject of personal data held by The
Greenwich Spa are entitled to:

Ask what information the company holds about them and
Ask how to gain access to
Be informed how to keep it up to
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 [email address]. The data controller
can supply a standard request form, although individuals do not have to
use this.

Individuals will be charged £10 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, the Data Protection Act allows personal data
to be disclosed to law enforcement agencies without the consent of the
data subject.

Under these circumstances, The Greenwich Spa 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
The Greenwich Spa 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.

[This is available on request. A version of this statement is also
available on the company’s website.]

Our Cookie Policy
Mydetoxdiet is committed to protecting and respecting your privacy, and
making our website as good as we possibly can, to this end we sometimes
place small data files on your computer. These files are known as
cookies. Nearly all big websites do this, but why?

Cookies can help websites improve things by:
– Remembering settings, so you don’t have to keep re-entering them
whenever you visit a new page

– Remembering information, you’ve given (e.g. your postcode) so you
don’t need to keep entering it

– Measuring how you use the website so we can make sure it meets your

– Managing which adverts you see on websites

Our cookies aren’t used to identify you personally. They’re just here to
make the site work better for you. Indeed, you can manage and/or delete
these small files as you wish.

– Remembering settings, so you don’t have to keep re-entering them
whenever you visit a new page

– Remembering information, you’ve given (e.g. your postcode) so you
don’t need to keep entering it

– Measuring how you use the website so we can make sure it meets your

– Managing which adverts you see on websites

To learn more about cookies and how to manage them, visit Or please read on to find out more about how and where
we use cookies.

How we use cookies on our website uses cookies in several places – we’ve listed each
of them below with more details about why we use them and how long they
will last. We do not use advertising or behavioral re-targeting cookies
on this site.

Removing and disabling cookies on your browser
If you do not wish to accept cookies on to your computer, you can
disable them by adjusting the settings on your browser. However, this
will affect the functionality of other websites you might visit.

Removing and disabling cookies on your browser
– Analytics Cookies

– Social site Cookies

Measuring website usage (Google Analytics)
We use Google Analytics to collect information about how people use this
site. We do this to make sure it’s meeting its users’ needs and to
understand how we could do it better.

Google Analytics stores information about what pages you visit, how long
you are on the site, how you got here and what you click on. We do not
collect or store your personal information (e.g. your name or address)
so this information cannot be used to identify who you are. We do not
allow Google to use or share our analytics data.