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Privacy Policy continued


When VH collects, holds and uses an individual's personal data that individual has the following the rights over that data. VH will ensure her data processes comply with those rights and will make all reasonable efforts to fulfil requests from an individual in relation to those rights.

Individual's rights

Right to be informed: whenever VH collects data she will provide a clear and specific privacy statement explaining why it is being collected and how it will be used.

Right of access: individuals can request to see the data VH holds on them and confirmation of how it is being used. Requests should be made in writing to VH and will be complied with free of charge and within one month. Where requests are complex or numerous this may be extended to two months

Right to rectification: individuals can request that their data be updated where it is inaccurate or incomplete. Right to object: individuals can object to their data being used for a particular purpose. VH will always provide a way for an individual to withdraw consent in all marketing communications. Where VH receives a request to stop using data she will comply unless she has a lawful reason to use the data for legitimate interests or contractual obligation. Right to erasure: individuals can request for all data held on them to be deleted. VH's data retention policy will ensure data is not held for longer than is reasonably necessary in relation to the purpose it was originally collected.

If a request for deletion is made she will comply with the request unless: There is a lawful reason to keep and use the data for legitimate interests or contractual obligation. There is a legal requirement to keep the data.

Right to restrict processing: individuals can request that their personal data be 'restricted' - that is, retained and stored but not processed further (e.g. if they have contested the accuracy of any of their data, VH will restrict the data while it is verified).


Data retention policy  

This policy sets out how VH will approach data retention and establishes processes to ensure data is not held for longer than is necessary. It forms part of VH's Data Protection Policy.


Roles and responsibilities

VH is the Data Controller and will determine what data is collected, retained and how it is used. She is responsible for the secure and fair retention and use of data. A regular review of all data will take place to establish if VH still has good reason to keep and use the data held at the time of the review.

As a general rule a data review will be held every 2 years and no more than 27 calendar months after the last review. The first review took place on 15th April 2018.


Data to be reviewed

Digital documents (e.g. spreadsheets) stored on personal devices

Data stored on third party online services e.g. Google Drive. The review will be conducted by VH.


How data will be deleted

Physical data will be destroyed safely and securely, including shredding.

All reasonable and practical efforts will be made to remove data stored digitally.

Priority will be given to any instances where data is stored in active lists (e.g. where it could be used) and to sensitive data.

Where deleting the data would mean deleting other data that VH has a valid lawful reason to keep (e.g. on old emails) then the data may be retained safely and securely but not used.


Statutory Requirements

Date stored by VH may be retained based in statutory requirements for storing data other than data protection regulations.

This might include but is not limited to:

Details of payments made and received (e.g. in bank statements and accounting records)

Contracts and agreements with suppliers/customers  


Mailing list data

If an individual opts out of a mailing list their data will be removed as soon as is practically possible.

All other data will be stored safely and securely and reviewed as part of the next two year review