la confidentialité

Data Protection Policy

TABLE OF CONTENTS

1. Policy statement ....................................................................................................................... 1

2. About this policy ....................................................................................................................... 1

3. Definition of data protection terms .......................................................................................... 2

4. Data protection principles ........................................................................................................ 2

5. Fair and lawful processing ........................................................................................................ 3

6. Processing for limited purposes................................................................................................ 3

7. Adequate, relevant and non-excessive processing................................................................... 3

8. Accurate data ............................................................................................................................ 4

9. Data retention........................................................................................................................... 4

10. Processing in line with data subjects' rights ............................................................................. 4

11. Data security ............................................................................................................................. 4

12 .Subject access requests ............................................................................................................ 5

13. Providing information to third parties ...................................................................................... 5

14. Monitoring and review of the policy ........................................................................................ 6

i

1. DEFINITIONS

1.1 The definitions and rules of interpretation in this clause apply in this agreement.

Association: the unincorporated association known at the “HypnoHome Association”

which is governed by the rules contained in this agreement, which represents a contract

between the Members.

Founding Member: HypnoHome Limited a company incorporated in England and Wales

(registered number 08971137) whose registered office is at Lynton House, 7-12 Tavistock

Square, London WC1H 9BQ.

Members: the hypnotists who have registered their details on the Website, paid an initial

subscription fee and been approved by the Founding Member in accordance with the

terms of this agreement.

1. POLICY STATEMENT

1.1 Everyone has rights with regard to how their personal information is handled. During the

course of our activities we will collect, store and process personal information about our

Members, customers, suppliers and other third parties. We recognise the need to treat it in

an appropriate and lawful manner.

1.2 Any breach of this policy will be taken seriously and may result in expulsion from the

Association.

2. ABOUT THIS POLICY

2.1 The types of information that we may be required to handle include details of Members,

customers and others that we communicate with. The information, which may be held on

paper or on a computer or other media, is subject to certain legal safeguards specified in

the Data Protection Act 1998 (the Act) and other regulations. The Act imposes restrictions

on how we may use that information.

2.2 It sets out our rules on data protection and the legal conditions that must be satisfied in

relation to the obtaining, handling, processing, storage, transportation and destruction of

personal information.

2.3 This policy may be amended at any time.

2.4 Any questions or concerns about the operation of this policy should be referred in the first

instance to the Founding Member.

2.5 If you consider that the policy has not been followed in respect of personal data about

yourself or others you should raise the matter with the Founding Member.

3. DEFINITION OF DATA PROTECTION TERMS

3.1 Data is information which is stored electronically, on a computer, or in certain paper-based

filing systems.

3.2 Data subjects for the purpose of this policy include all living individuals about whom we

hold personal data. A data subject need not be a UK national or resident. All data subjects

have legal rights in relation to their personal data.

3.3 Personal data means data relating to a living individual who can be identified from that

data (or from that data and other information in our possession). Personal data can be

factual (such as a name, address or date of birth) or it can be an opinion.

3.4 Data controllers are the people who or organisations which determine the purposes for

which, and the manner in which, any personal data is processed. They have a

responsibility to establish practices and policies in line with the Act. We are the data

controller of all personal data used in our business.

3.5 Data users include employees whose work involves using personal data. Data users have a

duty to protect the information they handle by following our data protection and security

policies at all times.

3.6 Data processors include any person who processes personal data on behalf of a data

controller.

3.7 Processing is any activity that involves use of the data. It includes obtaining, recording or

holding the data, or carrying out any operation or set of operations on the data including

organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also

includes transferring personal data to third parties.

3.8 Sensitive personal data includes information about a person's racial or ethnic origin,

political opinions, religious or similar beliefs, trade union membership, physical or mental

health or condition or sexual life, or about the commission of, or proceedings for, any

offence committed or alleged to have been committed by that person, the disposal of such

proceedings or the sentence of any court in such proceedings. Sensitive personal data can

only be processed under strict conditions, and will usually require the express consent of

the person concerned.

4. DATA PROTECTION PRINCIPLES

4.1 Anyone processing personal data must comply with the eight enforceable principles of

good practice. These provide that personal data must be:

4.1.1 Processed fairly and lawfully.

4.1.2 Processed for limited purposes and in an appropriate way.

4.1.3 Adequate, relevant and not excessive for the purpose.

4.1.4 Accurate.

4.1.5 Not kept longer than necessary for the purpose.

4.1.6 Processed in line with data subjects' rights.

4.1.7 Secure.

4.1.8 Not transferred to people or organisations situated in countries without

adequate protection.

5. FAIR AND LAWFUL PROCESSING

5.1 The Act is intended not to prevent the processing of personal data, but to ensure that it is

done fairly and without adversely affecting the rights of the data subject. The data subject

must be told who the data controller is (in this case Hypnohome Limited), the purpose for

which the data is to be processed, and the identities of anyone to whom the data may be

disclosed or transferred.

5.2 For personal data to be processed lawfully, certain conditions have to be met. These may

include, among other things, requirements that the data subject has consented to the

processing, or that the processing is necessary for the legitimate interest of the data

controller or the party to whom the data is disclosed. When sensitive personal data is

being processed, more than one condition must be met. In most cases the data subject's

explicit consent to the processing of such data will be required.

5.3 Data about Members, customers and other third parties may be processed for training and

quality purposes.

6. PROCESSING FOR LIMITED PURPOSES

Personal data will only be processed for the specific purposes notified to the data subject

when the data was first collected or for any other purposes specifically permitted by the

Act. This means that personal data will not be collected for one purpose and then used for

another. If it becomes necessary to change the purpose for which the data is processed,

the data subject will be informed of the new purpose before any processing occurs.

7. ADEQUATE, RELEVANT AND NON-EXCESSIVE PROCESSING

Personal data will only be collected to the extent that it is required for the specific purpose

notified to the data subject. Any data which is not necessary for that purpose will not be

collected in the first place.

8. ACCURATE DATA

Personal data will be accurate and kept up to date. Information which is incorrect or

misleading is not accurate and steps will therefore be taken to check the accuracy of any

personal data at the point of collection and at regular intervals afterwards. Inaccurate or

out-of-date data will be destroyed.

9.DATA RETENTION

Personal data will not be kept longer than is necessary for the purpose. This means that

data will be destroyed or erased from our systems when it is no longer required.

10. PROCESSING IN LINE WITH DATA SUBJECTS' RIGHTS

10.1 Data will be processed in line with data subjects' rights. Data subjects have a right to:

10.1.1 Request access to any data held about them by a data controller.

10.1.2 Prevent the processing of their data for direct-marketing purposes.

10.1.3 Ask to have inaccurate data amended.

10.1.4 Prevent processing that is likely to cause unwarranted substantial damage or

distress to themselves or anyone else.

10.1.5 Object to any decision that significantly affects them being taken solely by a

computer or other automated process.

11. DATA SECURITY

11.1 We will ensure that appropriate security measures are taken against unlawful or

unauthorised processing of personal data, and against the accidental loss of, or damage to,

personal data.

11.2 The Act requires us to put in place procedures and technologies to maintain the security of

all personal data from the point of collection to the point of destruction. Personal data may

only be transferred to a third-party data processor if he agrees to comply with those

procedures and policies, or if he puts in place adequate measures himself.

11.3 Maintaining data security means guaranteeing the confidentiality, integrity and availability

of the personal data, defined as follows:

11.3.1

Confidentiality means that only people who are authorised to use the data can

access it.

11.3.2 11.3.3

11.4

Integrity means that personal data should be accurate and suitable for the

purpose for which it is processed.

Availability means that authorised users should be able to access the data if they

need it for authorised purposes. Personal data should therefore be stored on our

central computer system instead of individual PCs.

Security procedures include:

11.4.1 11.4.2 Secure lockable desks and cupboards. Desks and cupboards should be kept

locked if they hold confidential information of any kind. (Personal information is

always considered confidential.)

11.4.3 Methods of disposal. Paper documents should be shredded. Floppy disks and CD-

ROMs should be physically destroyed when they are no longer required.

11.4.4 Entry controls. Any stranger seen in entry-controlled areas should be reported.

Equipment. Data users should ensure that individual monitors do not show

confidential information to passers-by and that they log off from their PC when it

is left unattended.

12. SUBJECT ACCESS REQUESTS

A formal request from a data subject for information that we hold about them must be

made in writing. A £10 fee is payable by the data subject for provision of this information.

Any member of staff who receives a written request should forward it to the Founding

Member immediately.

13. PROVIDING INFORMATION TO THIRD PARTIES

13.1 Any Member dealing with enquiries from third parties should be careful about disclosing

any personal information held by us. In particular they should:

13.1.1 Check the identity of the person making the enquiry and whether they are legally

entitled to receive the information they have requested.

13.1.2 Suggest that the third party put their request in writing so the third party's

identity and entitlement to the information may be verified.

13.1.3 Refer to the Founding Memberfor assistance in difficult situations.

13.1.4 Where providing information to a third party, do so in accordance with the eight

data protection principles.

14. MONITORING AND REVIEW OF THE POLICY

This policy is reviewed annually by our board of directors to ensure it is achieving its stated

objectives.