POLICY STATEMENT
1.1. Leo Care Services Ltd is committed to a policy of protecting the rights and privacy of our
staff, clients and others, in accordance with the General Data Protection Regulation
(GDPR) May 2018.
1.2. The new regulatory environment demands higher transparency and accountability in
how our business manage and use personal data. It also accords stronger rights for
individuals to understand and control that use.
1.3. The GDPR contains provisions that Leo Care Services Ltd will need to be aware of as data
controllers, including provisions intended to enhance the protection of our staff and
clients’ personal data. The GDPR requires that we must ensure that our privacy notices
are written in a clear, plain way that staff and clients will understand.
1.4. To comply with various legal obligations, including the obligations imposed on it by the
General Data Protection Regulation (GDPR) Leo Care Services Ltd must ensure that all
this information about individuals is collected and used fairly, stored safely and securely,
and not disclosed to any third party unlawfully.
2. COMPLIANCE
2.1. This policy applies to all staff of Leo Care Services Ltd. Any breach of this policy or of the
Regulation itself will be considered an offence and Leo Care Services Ltd.’s disciplinary
procedures will be invoked.
2.2. As a matter of best practice, other agencies and individuals working with Leo Care
Services Ltd and who have access to personal information, will be expected to read and
comply with this policy.
2.3. The policy will be updated as necessary to reflect best practice in data management,
security and control and to ensure compliance with any changes or amendments to the
GDPR and other relevant legislation.
3. GENERAL DATA PROTECTION REGULATION (GDPR)
3.1. The GDPR regulates the processing of personal data and protects the rights and privacy
of all living individuals (including children), for example by giving all individuals who are
the subject of personal data a general right of access to the personal data which relates
to them. Individuals can exercise the right to gain access to their information by means of
a ‘subject access request’.
3.2. Personal data is information relating to an individual and may be in hard or soft copy
(paper/manual files; electronic records; photographs; CCTV images) and may include
facts or opinions about a person.
3.3. The GDPR also sets out specific rights for staff and clients in relation to personal records
held within Leo Care Services Ltd’ system. For more detailed information on these regulations see the Data Protection Data Sharing Code of Practice (DPCoP) from the
Information Commissioner’s Office (ICO). Please follow this link to the ICO’s website
4. RESPONSIBILITIES UNDER THE GDPR
4.1. Leo Care Services Ltd is the ‘data controller’ under the terms of the legislation – this
means it is ultimately responsible for controlling the use and processing of the personal
data. Leo Care Services Ltd appoints a Data Protection Officer (DPO), is the director who
is available to address any concerns regarding the data held by Leo Care Services Ltd and
how it is processed, held and used.
4.2. The Senior Leadership Team is responsible for all day-to-day data protection matters and
will be responsible for ensuring that all members of staff and relevant individuals abide
by this policy, and for developing and encouraging good information handling within Leo
Care Services Ltd.
4.3. The Senior Leadership Team is also responsible for ensuring that Leo Care Services Ltd.’s
notification is kept accurate. Compliance with the legislation is the personal responsibility
of all members of Leo Care Services Ltd who process personal information.
4.4. Individuals who provide personal data to Leo Care Services Ltd are responsible for
ensuring that the information is accurate and up to date.
5. DATA PROTECTION PRINCIPLES
5.1. The legislation places a responsibility on every data controller to process any personal
data in accordance with the eight principles.
5.2. These eight principles are that personal data shall be
a) Processed lawfully, fairly and in a transparent manner in relation to the data subject
(‘lawfulness, fairness and transparency’);
b) 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, in accordance with Article 89(1), not be incompatible with the initial
purposes (‘purpose limitation’);
c) Adequate, relevant and limited to what is necessary in relation to the purposes for
which they are processed (‘data minimisation’).
d) 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 (‘accuracy’).
e) 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 in accordance with Article 89(1) subject to implementation of
the appropriate technical and organisational measures required by this Regulation in
order to safeguard the rights and freedoms of the data subject (‘storage limitation’)
held within Leo Care Services Ltd’ system. For more detailed information on these egulations see the Data Protection Data Sharing Code of Practice (DPCoP) from the
f) 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 (‘integrity and confidentiality’).
5.3. To comply with its obligations, Leo Care Services Ltd undertakes to adhere to the eight
principles:
6. PROCESS PERSONAL DATA FAIRLY AND LAWFULLY.
6.1. Leo Care Services Ltd will make all reasonable efforts to ensure that individuals who are
the focus of the personal data (data subjects) are informed of the identity of the data
controller, the purposes of the processing, any disclosures to third parties that are
envisaged; given an indication of the period for which the data will be kept, and any
other information which may be relevant.
7. PROCESS THE DATA FOR THE SPECIFIC AND LAWFUL PURPOSE FOR WHICH IT COLLECTED THAT
DATA AND NOT FURTHER PROCESS THE DATA IN A MANNER INCOMPATIBLE WITH THIS
PURPOSE.
7.1. Leo Care Services Ltd will ensure that the reason for which it collected the data originally
is the only reason for which it processes those data, unless the individual is informed of
any additional processing before it takes place.
8. ENSURE THAT THE DATA IS ADEQUATE, RELEVANT AND NOT EXCESSIVE IN RELATION TO THE
PURPOSE FOR WHICH IT IS PROCESSED.
8.1. Leo Care Services Ltd will not seek to collect any personal data which is not strictly
necessary for the purpose for which it was obtained. Forms for collecting data will always
be drafted with this mind. If any irrelevant data are given by individuals, they will be
destroyed immediately.
9. KEEP PERSONAL DATA ACCURATE AND, WHERE NECESSARY, UP TO DATE.
9.1. Leo Care Services Ltd will review and update all data on a regular basis. It is the
responsibility of the individuals giving their personal data to ensure that this is accurate,
and everyone should notify Leo Care Services Ltd if, for example, a change in
circumstances mean that the data needs to be updated.
9.2. It is the responsibility of Leo Care Services Ltd to ensure that any notification regarding
the change is noted and acted on.
10. ONLY KEEP PERSONAL DATA FOR AS LONG AS IS NECESSARY.
10.1. Leo Care Services Ltd undertakes not to retain personal data for longer than is necessary
to ensure compliance with the legislation, and any other statutory requirements. This
means Leo Care Services Ltd will undertake a regular review of the information held and
implement a weeding process.
10.2. Leo Care Services Ltd will dispose of any personal data in a way that protects the rights
and privacy of the individual concerned (e.g. secure electronic deletion, shredding and
disposal of hard copy files as confidential waste). A log will be kept of the records
destroyed.
11. PROCESS PERSONAL DATA IN ACCORDANCE WITH THE RIGHTS OF THE DATA SUBJECT UNDER
THE LEGISLATION.
11.1. Individuals have various rights under the legislation including a right to:
a) Be told the nature of the information Leo Care Services Ltd holds and any parties to
whom this may be disclosed.
b) Prevent processing likely to cause damage or distress.
c) Prevent processing for purposes of direct marketing.
d) Pe informed about the mechanics of any automated decision-making process that will
significantly affect them.
e) Not have significant decisions that will affect them taken solely by automated process.
f) Sue for compensation if they suffer damage by any contravention of the legislation.
g) Act to rectify, block, erase or destroy inaccurate data.
h) Request that the Office of the Information Commissioner assess whether any provision
of the Act has been contravened.
11.2. Leo Care Services Ltd will only process personal data in accordance with individuals’
rights.
12. PUT APPROPRIATE TECHNICAL AND ORGANISATIONAL MEASURES IN PLACE AGAINST
UNAUTHORISED OR UNLAWFUL PROCESSING OF PERSONAL DATA, AND AGAINST ACCIDENTAL
LOSS OR DESTRUCTION OF DATA.
12.1. All members of staff are responsible for ensuring that any personal data which they hold
is kept securely and not disclosed to any unauthorised third parties.
12.2. Leo Care Services Ltd will ensure that all personal data is accessible only to those who
have a valid reason for using it.
12.3. Leo Care Services Ltd will have in place appropriate security measures by
a. Ensuring that hard copy personal data is kept in lockable filing cabinets/cupboards
with controlled access (with the keys then held securely in a key cabinet with
controlled access):
b. Keeping all personal data in a lockable cabinet with key-controlled access.
c. password protecting personal data held electronically.
d. Archiving personal data which are then kept securely (lockable cabinet).
e. Placing any PCs or terminals, CCTV camera screens etc. that show personal data so
that they are not visible except to authorised staff.
f. Ensuring that PC screens are not left unattended without a password protected
screensaver being used.
12.4. In addition, Leo Care Services Ltd will put in place appropriate measures for the deletion
of personal data - manual records will be shredded or disposed of as ‘confidential waste’
and appropriate contract terms will be put in place with any third parties undertaking
this work. Hard drives of redundant PCs will be wiped clean before disposal or if that is
not possible, destroyed physically. A log will be kept of the records destroyed.
12.5. This policy also applies to staff who process personal data ‘off-site’, e.g. when working at
home, and in circumstances additional care must be taken regarding the security of the
data.
13. TRANSFERING DATA OUTSIDE EUROPEAN ECONOMIC AREA(EEA)
13.1. Leo Care Services Ltd will ensure that no personal data is transferred to a country or a
territory outside the European Economic Area (EEA) unless that country or territory
ensures adequate level of protection for the rights and freedoms of data subjects in
relation to the processing of personal data.
13.2. Leo Care Services Ltd will not transfer data to such territories without the explicit consent of the individual.
13.3. This also applies to publishing information on the Internet - because transfer of data can
include placing data on a website that can be accessed from outside the EEA - so Leo
Care Services Ltd will always seek the consent of individuals before placing any personal
data (including photographs) on its website.
13.4. If Leo Care Services Ltd collects personal data in any form via its website, it will provide a
clear and detailed privacy statement prominently on the website, and wherever else
personal data is collected.
14. CONSENT AS A BASIS FOR PROCESSING
14.1. Although it is not always necessary to gain consent from individuals before processing
their data, it is often the best way to ensure that data is collected and processed in an
open and transparent manner.
14.2. Consent is especially important when Leo Care Services Ltd is processing any sensitive
data, as defined by the legislation.
14.3. Leo Care Services Ltd understands consent to mean that the individual has been fully
informed of the intended processing and has signified their agreement whilst being of a
sound mind and without having any undue influence exerted upon them. Consent
obtained based on misleading information will not be a valid basis for processing.
Consent cannot be inferred from the non-response to a communication.
15. PERSONAL DETAILS
15.1. For the purposes of the General Data Protection Regulation (GDPR)(Regulation (EU)
2016/679 you consent to Leo Care Services Ltd holding and processing personal data
including sensitive personal data of which you are the subject, details of which are specified
in Leo Care Services Ltd.’s data protection policy and this include marketing images and Leo
Care Services Ltd CCTV.”
15.2. Leo Care Services Ltd will ensure that any forms used to gather data on an individual will
contain a statement (fair collection statement) explaining the use of that data, how the
data may be disclosed and indicate whether the individual needs to consent to the
processing.
15.3. Information may be shared with third parties will take place only where the law allows it
and the sharing follows the Data Protection Act 1998.
15.4. Further information about use of and access to your personal data, and details of
organisations with whom we regularly share data are available at:
https://www.gov.uk/government/publications/esfa-privacy-notice
15.5. Leo Care Services Ltd will ensure that if the individual does not give his/her consent for
the processing, and there is no other lawful basis on which to process the data, then
steps will be taken to ensure that processing of that data does not take place.
16. SUBJECT ACCESS RIGHTS (SARS)
16.1. Individuals have a right to access any personal data relating to them which are held by
Leo Care Services Ltd. Any individual wishing to exercise this right should apply in writing
to the managing director.
16.2. Under the terms of the legislation, any such requests must be complied with within 40
days.
17. DISCLOSURE OF DATA
17.1. Only disclosures which have been notified under Leo Care Services Ltd.’s DP notification
must be made and therefore staff should exercise caution when asked to disclose
personal data held on another individual or third party.
17.2. Leo Care Services Ltd undertakes not to disclose personal data to unauthorised third
parties, including family members, friends, government bodies and in some
circumstances, the police.
17.3. Legitimate disclosures may occur in the following instances:
a. the individual has given their consent to the disclosure.
b. the disclosure has been notified to the OIC and is in the legitimate interests of Leo
Care Services Ltd.
c. the disclosure is required for the performance of a contract.
17.4. There are other instances when the legislation permits disclosure without the consent of
the individual. For detailed guidance on disclosures see the Code of Practice (CoP).
17.5. In no circumstances will Leo Care Services Ltd sell any of its databases to a third party.
18. PUBLICATION OF ORGANISATIONAL INFORMATION
18.1. Leo Care Services Ltd publishes various items which will include some personal data, e.g.
internal telephone directory, event information, photos and information in marketing
materials.
18.2. It may be that in some circumstances an individual wishes their data processed for such
reasons to be kept confidential, or restricted organisational access only. Therefore, it is
Leo Care Services Ltd policy to offer an opportunity to opt-out of the publication of such
when collecting the information.
19. EMAIL
19.1. It is the policy of Leo Care Services Ltd to ensure that senders and recipients of email are
made aware that under the DPA, and Freedom of Information Legislation, the contents of
email may have to be disclosed in response to a request for information. One means by
which this will be communicated will be by a disclaimer on Leo Care Services Ltd.’s email.
19.2. Under the Regulation of Investigatory Powers Act 2000, Lawful Business Practice
Regulations, any email sent to or from Leo Care Services Ltd may be accessed by
someone other than the recipient for system management and security purposes.
20. CCTV
20.1. Leo Care Services Ltd may install some CCTV systems to operate within Leo Care Services
Ltd for protecting staff and visitors to our offices. Leo Care Services Ltd will only process
personal data obtained by the CCTV system in a manner which ensures compliance with
the legislation.
21. PROCEDURE FOR REVIEW
21.1. This policy will be updated as necessary to reflect best practice or future amendments
made to the General Data Protection Regulation (GDPR) May 2018 and Data Protection
Act 1998.
21.2. Please follow this link to the ICO’s website (www.ico.gov.uk) which provides further
detailed guidance on a range of topics including individuals’ rights, exemptions from the
Act, dealing with subject access requests, how to handle requests from third parties for
personal data to be disclosed etc. You may find it helpful to read the Guide to Data
Protection which is available from the website.
Leo Care Services Ltd
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