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: 24/05/2019



The Greenwich Spa needs to gather and use certain information about individuals.

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

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:

  1. Be processed fairly and lawfully
  2. Be obtained only for specific, lawful purposes
  3. Be adequate, relevant and not excessive
  4. Be accurate and kept up to date
  5. Not be held for any longer than necessary
  6. Processed in accordance with the rights of data subjects
  7. Be protected in appropriate ways
  8. 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 inappropriately.
  • 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 and
    • Reviewing all data protection procedures and related policies, in line with an agreed
    • Arranging data protection training and advice for the people covered by this
    • Handling data protection questions from staff and anyone else covered by this
    • 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 like
    • 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 shared.
  • 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 possible.

  • 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 company
  • 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 needs

– 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 needs

– 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.