Privacy Statement Policy and Procedure

Introduction

This privacy policy explains how personal data is collected and used when you use our website. It also explains how we process any data that you supply to us on this website, for instance to request a quote or to use our online services.

GPS Health Online is the Data Controller for any personal data that you supply to us as part of the services you are contracted to receive from us. As our client, you are our data subject.

Policy Statement

We are committed to protecting your privacy. You can access our website without giving us any information about yourself. But sometimes we do need information to provide services that you request, and this statement of privacy explains data collection and use in those situations.

In general, you can visit our web site without telling us who you are and without revealing any information about yourself. However, there may be occasions when you choose to give us personal information, for example, when you choose to contact us or request information from us. We will ask you when we need information that personally identifies you or allows us to contact you.

We collect the personal data that you may volunteer while using our services. We do not collect information about our visitors from other sources, such as public records or bodies, or private GPS Health Online. We do not collect or use personal data for any purpose other than that indicated below:

• To send you confirmation of requests that you have made to us
• To send you information when you request it.

We intend to protect the quality and integrity of your personally identifiable information and we have implemented appropriate technical and GPS Health Onlineal measures to do so. We ensure that your personal data will not be disclosed to State institutions and authorities except if required by law or other regulation.

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should be aware that we don’t have any control over the other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting these sites.

• Our address is: info@gpshealthonline.lk
  Email: info@gpshealthonline.lk 
• GPS Health Online has a Data Protection Officer who can be contacted via:
  Email: info@gpshealthonline.lk

What personal data we collect

We will obtain personal data about you (such as your name, address, email address, telephone number) whenever you complete an online form.For example, we will obtain your personal data when you register to use the Site, send us feedback, post material, contact us for any reason, sign up to a service, enter a competition, purchase goods or services or as part of the provision of your existing contractual services

We may monitor your use of this website through the use of cookies and similar tracking devices. For example, we may monitor how many times you visit, which pages you go to, traffic data, location data, weblogs and other communication data whether required for billing purposes or otherwise, the originating domain name of a user’s internet service provider, IP address, operating system, browser type. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. Please see further the section on ‘Use of cookies’ below.

Occasionally we may receive information about you from other sources (such as credit reference agencies) which we will add to the information which we already hold about you in order to help us provide goods and services.

What we do with your personal data

We will use your personal data for any one or more of the following purposes: to help us identify you and any accounts you hold with us; administration; research, statistical analysis and behavioural analysis; customer profiling and analysing your purchasing preferences; marketing—see ‘Marketing and opting out’ below; fraud prevention and detection; to prevent and/or detect crime; billing and order fulfilment; credit scoring and credit checking—see ‘Credit checking’ below; customising this Site and its content to your particular preferences; to notify you of any changes to this Site or to our goods and services which may affect you; improving our goods and services; to allow you to participate in interactive features of the Site; in the event we sell or buy any business or assets.

The following table sets out how we handle your personal data and our legal basis for doing so under GDPR and the Data Protection Act 2018.

If this includes information about your physical or mental health, such information (being sensitive personal data, Special Category data), will only be used by us, with your explicit consent, to assess your eligibility for Reasonable Adjustments. We will not share or disclose it to others.
You can withdraw your consent as anytime by contacting us. Please note that we may not be able to process your request for Reasonable Adjustments if you do this.

The following table sets out the categories of personal data that we obtain.

We may collect, hold, use and disclose the information collected to compile statistical data and to; maintain our database; develop/improve our website; respond to any email enquiries; notify you of any upcoming marketing, training or other events that you have opted in to; provide you with publications; manage quality control; manage systems administration; attend to compliance issues; provide you or your GPS Health Online with advice and determine suitability for employment.

We will not use or disclose your personal information for any other purpose which is not related (or in the case of sensitive information, directly related) to the above purposes without your consent, unless otherwise authorised, required or permitted under the laws of England and Wales. GPS Health Online does not sell your data to third parties.

If you no longer wish to receive information about our services, please send an email to our GPS Health Online Data Protection and Compliance Officer (admin@gpshealthonline.com) advising that you do not wish to receive further information.

Will we disclose your data?

Personal data will only be disclosed on a confidential basis to external service providers so that they can provide services such as financial or administrative services in connection with the operation of our business; and to any person (where necessary) in connection with their services, such as law enforcement, regulatory authorities, partners or advisors within the UK.

The handling of these operations is governed by a data processing contract between us and our external service provider, ensuring a commitment to the principals of the GDPR and the Data Protection Act 2018. We ensure external service providers are only authorised to use personal data for the limited purposes specified in our agreement with them.

GPS Health Online implements the following technical, physical and organizational measures to maintain the safety of your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized use, unauthorized modification, disclosure or access and against all other unlawful forms of processing.

Availability

GPS Health Online utilises the extensive features of the cloud environment to ensure high availability, like full redundancy, load balancing, automatic capacity scaling, continuous data backup and geo-replication along with a traffic manager for automatic geographical failover on datacenter level disasters. All failover mechanisms are fully automated.

No personal data is stored permanently outside GPS Health Online’s cloud platforms. The physical security is thereby maintained by GPS Health Online’s subcontractors, see clause 7. Microsoft’s datacenters comply with industry standards such as ISO 27001 for physical security and availability, e.g. by using security staff around the clock, two-factor access control using biometric and card readers, barriers, fencing, security cameras and other measures.

Integrity

To ensure integrity, all data transits are encrypted to align with best practices for protecting confidentiality and data integrity. E.g. all supplied credit card information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway provider’s database only to be accessible by those who are authorized to access such systems and who are required to keep the information confidential.

For data in transit, the Service uses industry-standard transport protocols between devices and Microsoft datacenters and within datacenters themselves.

Confidentiality

All personnel are subject to full confidentiality and any subcontractors and subprocessors are required to sign a confidentiality agreement if not full confidentiality is part of the main agreement between the parties.

Whenever personal data is accessed by authorised personnel, the access is only possible over an encrypted connection. When accessing the data in a database, the IP number of the person accessing the data must also be pre-authorized to obtain access.

Any device being used to access personal data is login protected by GPS Health Online’s Azure Active Directory (AAD), Microsoft’s cloud based identity and access management service, and has GPS Health Online’s corporate antivirus solution installed. If any personal data are temporarily stored on a device, the storage unit on the device must also be strongly encrypted.

On premise devices storing personal data temporarily is at all times, except when not being actively used or relocated under uninterrupted supervision, locked in a safe. Personal data are never stored on mobile media like USB sticks and DVD’s.

Transparency

GPS Health Online will at all times keep you informed about changes to the processes to protect data privacy and security, including practices and policies. You may at any time request information on where and how data is stored, secured and used. GPS Health Online will also provide the summaries of any independent audits of the Service.

Isolation

All access to personal data is blocked by default, using a zero privileges policy. Access to personal data is restricted to individually authorized personnel. GPS Health Online’s Security and Privacy Officer issues authorizations and maintains a log of granted authorizations. Authorized personnel are granted a minimum access on a need-to-have basis through our AAD.

How long we keep your personal data

Personal data from our data subjects is retained in line with our data retention policy. GPS Health Online keeps most data for 7 years, which covers the 6 years by law in which we have to keep certain information for a minimum of 6 years plus the current year. Personal data that is no longer necessary to be kept under GPS Health Online’s data retention policy will be deleted. Under GPS Health Online’s data retention policy, there are certain exemptions in relation to financial data and health data. A copy of GPS Health Online’s data retention policy can be made available upon request.

Your Rights

You have the following rights in relation to personal data held on you by GPS Health Online:

• The right to be informed about how personal data is used - (this notice)
• The right to access a copy of personal data that GPS Health Online holds about you
• The right to rectification of any errors in personal data held by GPS Health Online
• The right to erasure of any personal data
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision-making including profiling

How to contact us

Please review the website regularly as this statement may change from time to time.  If you have any questions about our privacy policy or information, we hold about you please contact:

GPS Health Online Data Protection and Compliance Officer

Email: info@gpshealthonline.lk