Policys and Procedures

Appointments

We ask that clients arrive 10 minutes prior to the appointment time given to fill out registration forms etc. The appointment length for jewellery and castings is 30 to 45 minutes depending on which package you choose. This is to allow for preparation and the castings to take place. If babies are not be in an ideal position, the length of appointment will allow time for the baby to hopefully change position, we encourage clients to move or walk around in order to get the best views of the baby. It is important to remember that even with all of our technology and the most skilful Sonographers we still do not have full control over nature. Most mothers go home with the most amazing images and feel that they have really had a head start in bonding with their babies, although, there are those babies that often find it comfortable in a position that will not allow us to see faces or sometimes the sex of the baby. Unfortunately, refunds are not given if this is the case as payment is taken for use of the clinic technology and Sonographer time, we will however, offer one further complimentary appointment. We are able to accommodate up to 4 members of clients family and friends at each scan appointment but we ask that small children and babies are accompanied by at least one adult.

 

Payment

Payment can be made preferably by credit/debit card. Cheques are not accepted. A non-refundable deposit will be requested when making an appointment.

 

Policies on refunds

We request a non-refundable deposit when appointment are booked of £20. This fee is to cover costs that are incurred when booking the expertise of our staff. If the service has been paid in full, we require for 48 hours’ notice.

 

Our policy is valid for a period of 30 calendar days from the date of the purchase. If you receive your order and are not satisfied for any reason you can return the product for a refund. If the period of 30 days has lapsed since the purchase, we can't, unfortunately, offer you a refund.

 

If you item was personalised, there is no refund available unless the item arrived damaged.

 

Refund requirements:

The following criteria must be met to qualify for a refund:

Product must be in original packaging

Product must be unused

Product must not be damaged

In order to ensure the above criteria has been met, all returns will be inspected. If the product does not meet the listed criteria, we reserve the right not to issue a refund.

 

Proof of purchase:

To complete your refund, we require a receipt, purchase order or other proof of purchase. Please note that without the aforementioned proof of purchase, we will not issue a refund but will provide you with a store credit instead.

 

Sale and clearance items:

Only regular priced items may be returned, unfortunately sale, special offer or clearance items cannot be returned.

 

Shipping items:

In order to return an order, you must contact us first.

 

Returns can be mailed to: The Precious Keepsake Company, 3 St Johns Parade, Goring By Sea, West Sussex, BN12 4HJ. You will be responsible for paying for the shipping costs with regard to the items that you wish to return. We will not refund the shipping costs.

 

You must take care to ensure that the goods are properly packaged so that they will not be damaged while in transit. If the product is found damaged or used beyond what it takes for us to reasonably inspect it, then we may reject a refund.

 

 

Complaints

Should any of our customers feel disheartened by our services, we are happy to listen, discuss and resolve any complaints. We will need to be notified by telephone or in writing and endeavour to deal with all complaints within 72 hours. The manager will call to discuss the matter in more detail. All written complaints should be posted to:

The Precious Keepsake Company

BeauPro ltd

3 st Johns Parade

Alinora Crescent

Goring By Sea

West Sussex

BN12 4HJ

Email address – info@thepreciouskeepsakecompany.co.uk

Telephone contact details – 01903 366466

 

 

 

Privacy policy

The Precious Keepsake Company, BeauPro ltd are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. We do not share our information. Any information held is for the purpose of client safety and will not be shared with any other companies unless specifically authorised to do so in writing. Any information that we hold on paper will be stored in a locked cabinet in a locked office with no access to the public, although most information that we collect is held electronically. We are registered with the Information Commissioners Office (ICO) in accordance with the Data Protection Act.

 

This Privacy Policy outlines The Precious Keepsake Company, Beau Pro ltd, ("we", "our" or "the Company") practices with respect to information collected from users who access our website at www.thepreciouskeepsakecompany.co.uk ("Site"), or otherwise share personal information with us (collectively: "Users"). 

Grounds for data collection 

Processing of your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter "Personal Information") is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.

 

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

 

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions. 

What information we collect?

We collect two types of data and information from Users. 

 

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

 

The second type of information Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

  • Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.

How do we receive information about you?

We receive your Personal Information from various sources:

  • When you voluntarily provide us your personal details in order to register on our Site;

  • When you use or access our Site in connection with your use of our services;

  • From third party providers, services and public registers (for example, traffic analytics vendors).

What information we collect?

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

 

We may use the information for the following:

  • Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have;

  • To communicate with you and to keep you informed of our latest updates and services;

  • To serve you advertisements when you use our Site (see more under "Advertisements"); 

  • To market our websites and products (see more under "Marketing"); 

  • Conducting statistical and analytical purposes, intended to improve the Site.

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.

 

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 

  • Hosting and operating our Site;

  • Providing you with our services, including providing a personalised display of our Site;

  • Storing and processing such information on our behalf; 

  • Serving you with advertisements and assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;

  • Providing you with marketing offers and promotional materials related to our Site and services; 

  • Performing research, technical diagnostics or analytics;

We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

User Rights

You may request to: 

  1. Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information. 

  2. Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format. 

  3. Request rectification of your personal information that is in our control.

  4. Request erasure of your personal information. 

  5. Object to the processing of personal information by us. 

  6. Request to restrict processing of your personal information by us.

  7. Lodge a complaint with a supervisory authority.

 

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. 

 

If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer (“DPO”) using the details provided below:

samantha@beaupro.co.uk

Retention

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations. 

 

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

 

A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

 

The Site uses the following types of cookies:

 

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

 

b. 'persistent cookies' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

 

c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

 

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

 

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

 

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy. 

Marketing

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you.  

 

Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists. 

 

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Minors

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorisation by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at info@thepreciouskeepsakecompany.co.uk

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at

info@thepreciouskeepsakecompany.co.uk

01903 366466

The Precious Keepsake Company

Beau Pro Ltd

3 St Johns Parade

Alinora Crescent

Goring By Sea

West Sussex

BN12 4HJ

 

Last Modified June 2020

and beyond. Whatever keepsake you are looking to create for

Privacy and Data control in more detail:

 

1. Introduction This Policy sets out the obligations of BeauPro Ltd, a company registered in England under number 09610581, whose registered office is at 3 st Johns Parade, Alinora Crescent, Goring By Sea, West Sussex, BN12 4HJ (“the Company”) regarding data protection and the rights of its Clients (in this context, “Client Data Subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”). The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data relating to employee data subjects. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company. The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

2. The Data Protection Principles This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:

2.1 Processed lawfully, fairly, and in a transparent manner in relation to the data subject.

2.2 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 not be considered to be incompatible with the initial purposes.

2.3 Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.

2.4 Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.

2.5 Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is 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, subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject.

2.6 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.

3. The Rights of Data Subjects the GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):

3.1 The right to be informed (Part 12).

3.2 The right of access (Part 13);

3.3 The right to rectification (Part 14);

3.4 The right to erasure (also known as the ‘right to be forgotten’) (Part 15);

3.5 The right to restrict processing (Part 16);

3.6 The right to data portability (Part 17);

3.7 The right to object (Part 18); and

3.8 Rights with respect to automated decision-making and profiling (Parts 19 and 20).

4. Lawful, Fair, and Transparent Data Processing

4.1 The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies:

4.1.1 The data subject has given consent to the processing of their personal data for one or more specific purposes;

4.1.2 The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;

4.1.3 The processing is necessary for compliance with a legal obligation to which the data controller is subject;

4.1.4 The processing is necessary to protect the vital interests of the data subject or of another natural person;

4.1.5 The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or

4.1.6 The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

4.2 If the personal data in question is “special category data” (also known as “sensitive personal data” (for example, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation), at least one of the following conditions must be met:

4.2.1 The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);

4.2.2 The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law (insofar as it is authorised by EU or EU Member State law or a collective agreement pursuant to EU Member State law which provides for appropriate safeguards for the fundamental rights and interests of the data subject);

4.2.3 The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;

4.2.4 The data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal data is not disclosed outside the body without the consent of the data subjects;

4.2.5 The processing relates to personal data which is clearly made public by the data subject;

4.2.6 The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;

4.2.7 The processing is necessary for substantial public interest reasons, on the basis of EU or EU Member State law which shall be proportionate to the aim pursued, shall respect the essence of the right to data protection, and shall provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;

4.2.8 The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services on the basis of EU or EU Member State law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the GDPR;

4.2.9 The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of EU or EU Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy) 

4.2.10 The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR based on EU or EU Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

5. Specified, Explicit, and Legitimate Purposes 5.1 The Company collects and processes the personal data set out in Parts 21 to 25 of this Policy. This includes:

5.1.1 Personal data collected directly from Client data subjects.

5.2 The specific purposes for which the Company collects, processes, and holds such personal data are set out in Parts 21 to 25 of this Policy (or for other purposes expressly permitted by the GDPR).

5.3 Employee data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data. Please refer to Part 12 for more information on keeping data subjects informed.

6. Adequate, Relevant, and Limited Data Processing The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which Client data subjects have been informed (or will be informed) as under Part 5, above, and as set out in Parts 21 to 25, below.

7. Accuracy of Data and Keeping Data Up-to-Date Data collected form the client data subject should only be valid or the purpose/s specified in section 4 and all data is obtained from the client data subject. See section 6. 8. Data Retention

8.1 The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.

8.2 When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.

8.3 For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy.

9. Secure Processing The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided in Parts 26 to 31 of this Policy.

10. Accountability and Record-Keeping

10.1 The Company’s Data Protection Officer is Samantha Gilbert, email samantha@beaupro.co.uk

10.2 The Data Protection Officer shall be responsible, working together with the Assistant Clinic Manager, for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other employment and data protection-related policies, and with the GDPR and other applicable data protection legislation.

10.3 This document describes all records held and the Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:

10.3.1 The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors;

10.3.2 The purposes for which the Company collects, holds, and processes personal data; 10.3.3 Details of the categories of personal data collected, held, and processed by the Company, and the categories of Client data subject to which that personal data relates;

10.3.4 Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;

10.3.5 Details of how long personal data will be retained by the Company (please refer to the Company’s Data Retention Policy); and

10.3.6 Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

11. Data Protection Impact Assessments

11.1 The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data which involve the use of new technologies and the processing involved is likely to result in a high risk to the rights and freedoms of employee data subjects under the GDPR.

11.2 Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:

11.2.1 The type(s) of personal data that will be collected, held, and processed;

11.2.2 The purpose(s) for which personal data is to be used;

11.2.3 The Company’s objectives;

11.2.4 How personal data is to be used;

11.2.5 The parties (internal and/or external) who are to be consulted;

11.2.6 The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;

11.2.7 Risks posed to employee data subjects;

11.2.8 Risks posed both within and to the Company; and

11.2.9 Proposed measures to minimise and handle identified risks.

12. Keeping Data Subjects Informed

12.1 The following information shall be provided:

12.1.1 Details of the Company including, but not limited to, the identity of its Data Protection Officer;

12.1.2 The purpose(s) for which the personal data is being collected and will be processed (as detailed in Parts 21 to 25 of this Policy) and the legal basis justifying that collection and processing;

12.1.3 Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;

12.1.4 Where the personal data is not obtained directly from the Client data subject, the categories of personal data collected and processed;

12.1.5 Where the personal data is to be transferred to one or more third parties, details of those parties;

12.1.6 Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Part 32 of this Policy for further details);

12.1.7 Details of data retention;

12.1.8 Details of the Client data subject’s rights under the GDPR;

12.1.9 Details of the Client data subject’s right to withdraw their consent to the Company’s processing of their personal data;

12.1.10 Details of the Client data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the GDPR);

12.1.11 Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it; and

12.1.12 Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.

13. Data Subject Access

13.1 Client data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.

13.2 Clients wishing to make a SAR should do in writing to the Company’s Data Protection Officer at samantha@beaupro.co.uk

13.3 Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the client data subject shall be informed.

13.4 All SARs received shall be handled by the Company’s Data Protection Officer.

13.5 The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a client data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

14. Rectification of Personal Data

14.1 Client data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.

14.2 The Company shall rectify the personal data in question, and inform the Client data subject of that rectification, within one month of the client data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the employee data subject shall be informed.

14.3 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

15. Erasure of Personal Data

15.1 Client data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:

15.1.1 It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;

15.1.2 The Client data subject wishes to withdraw their consent to the Company holding and processing their personal data;

15.1.3 The Client data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 18 of this Policy for further details concerning the right to object);

15.1.4 The personal data has been processed unlawfully;

15.1.5 The personal data needs to be erased in order for the Company to comply with a particular legal obligation.

15.2 Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the client data subject informed of the erasure, within one month of receipt of the employee data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the client data subject shall be informed.

15.3 In the event that any personal data that is to be erased in response to a client data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

15.4 Information in the form of reports and supporting images from Early Pregnancy scans, Well-being scans will be held on file for a recommended period of 2 years accessible on request from the Client data subject. (see Part 4 of this Policy for a definition) Gender scan supporting images will be held for a period of 12 months unless otherwise directed by the data subject. All other types of image data will be deleted after a period of 1 month, consent forms will be retained for a period of 2 years. . (see Part 4 of this Policy for a definition)

16. Restriction of Personal Data Processing

16.1 Client data subjects may request that the Company ceases processing the personal data it holds about them. If a client data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.

16.2 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

17. Data Portability

17.1 The Company processes personal data relating to clients using hard copy means stored in a locked cupboard in a building with an alarm system. Only BeauPro Ltd employees who have signed and agreed date protection agreements are permitted access these files if there is a valid reason or on the request of the client data subject.

17.2 Where Client data subjects have given their consent to the Company to process their personal data in such a manner, or the processing is otherwise required for the performance of a contract between the Company and the Client data subject, Client data subjects have the right, under the GDPR, to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers). This should be requested and acknowledged in writing. .

17.3 Where technically feasible, if requested by a Client data subject, personal data shall be sent directly to the required data controller.

17.4 All requests for copies of personal data shall be complied with within one month of the Client data subject’s request. The period can be extended by up to two months in the case of complex or numerous requests. If such additional time is required, the Client data subject shall be informed.

18. Objections to Personal Data Processing

18.1 Client data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes.

18.2 Where a Client data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the employee data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.

18.3 Where an employee data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.

18.4 Where an employee data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the employee data subject must, under the GDPR, “demonstrate grounds relating to his or her particular situation”. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.

19. Personal Data the Company holds personal data that is directly relevant to its Clients. That personal data shall be collected, held, and processed in accordance with Client data subjects’ rights and the Company’s obligations under the GDPR and with this Policy. The Company may collect, hold, and process the personal data detailed in Parts 21 to 25 of this Policy:

19.1 Identification information relating to Clients:

19.1.1 Name;

19.1.2 Contact Details;

19.1.3 Current medical status/ current conditions.

19.1.4 Any medical history

19.1.5 Medication

19.1.6 Mental health

19.1.7 Disabilities

19.1.8 Any information that could identify the client

20. Health Records

20.1 The Company holds health records (information given on initial consent forms on client data subjects which are used to assess the health, wellbeing, and welfare of clients and to highlight any issues that may require further investigation.

20.2 In particular, the Company places a high priority on maintaining health and safety and appropriate implementation of protocols and procedures and on preventing discrimination on the grounds of disability or other medical conditions. In most cases, health data on employees falls within the GDPR’s definition of special category data (see Part 4 of this Policy for a definition).

21. Data Security - Transferring Personal Data and Communications The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data (including, but not limited to, personal data relating to employees):

21.1 All emails containing personal data must be encrypted via Egress or password protected documents.

21.2 All emails containing personal data must be marked “confidential”;

21.3 Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;

21.4 Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;

21.5 Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted.

21.6 Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using recorded signed for delivery

21.7 All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”.

22. Data Security - Storage The Company shall ensure that the following measures are taken with respect to the storage of personal data (including, but not limited to, personal data relating to clients):

22.1 All electronic copies of personal data should be stored securely on password encrypted files onsite and offsite.

22.2 All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar; .

23. Data Security – Disposal

23.1 When using the services of BeauPro ltd, the consent form that you are required to complete prior to using the services of BeauPro ltd will address deletion of images.

23.2 Images relating to handprint, footprint, fingerprint, drawn images, pawprints etc will be held for a period of 1 month unless otherwise directed by the client data subject. Permanent deletion will then take place.

23.3 When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of.

23.4 For further information on the deletion and disposal of personal data, deletion consists of complete digital deletion or shredding of documents.

23.5 After deletion has taken place access to the information will no longer be possible.

24. Data Security - Use of Personal Data The Company shall ensure that the following measures are taken with respect to the use of personal data:

24.1 No personal data may be shared informally. No personal data may be transferred to any family member, any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of Samantha Gilbert Data protection officer.

24.2 Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;

24.3 If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and

24.4 BeauPro Ltd does not use any personal data for marketing purposes unless appropriate consent has been obtained.

24.5 Information can only be shared with the express consent of the client data subject for the purposes of further investigation or ongoing care/management.

24.6 If consent is given BeauPro ltd reserves the right use anonymous images for the purposes of examples or social media or website, use.

25. Data Security - IT Security The Company shall ensure that the following measures are taken with respect to IT and information security:

25.1 All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols. All software used by the Company is designed to require such passwords.;

25.2 Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;

25.3 All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. The managing director shall be responsible for installing any and all security-related updates as required after the updates are made available by the publisher or manufacturer or as soon as reasonably and practically possible, unless there are valid technical reasons not to do so. 25.4 No software may be installed on any Company-owned computer or device without the prior approval of the Managing director.

26. Organisational Measures The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data: 26.1 All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under this Policy, and shall be provided with a copy of this Policy

; 26.2 Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;

26.3 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so; 26.4 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;

26.5 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;

26.6 Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;

26.7 All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;

26.8 The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;

26.9 All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract;

26.10 All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the GDPR; and

26.11 Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

27. Transferring Personal Data to a Country Outside the EEA

27.1 The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.

27.2 The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:

27.2.1 The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;

27.2.2 The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the GDPR); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;

27.2.3 The transfer is made with the informed consent of the relevant employee data subject(s);

27.2.4 The transfer is necessary for the performance of a contract between the employee data subject and the Company (or for pre-contractual steps taken at the request of the employee data subject);

27.2.5 The transfer is necessary for important public interest reasons;

27.2.6 The transfer is necessary for the conduct of legal claims;

27.2.7 The transfer is necessary to protect the vital interests of the employee data subject or other individuals where the employee data subject is physically or legally unable to give their consent; or

27.2.8 The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

28. Data Breach Notification

28.1 All personal data breaches must be reported immediately to the Company’s Data Protection Officer.

28.2 If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of Client data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.

28.3 In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 29.2) to the rights and freedoms of employee data subjects, the Data Protection Officer must ensure that all affected employee data subjects are informed of the breach directly and without undue delay.

28.4 Data breach notifications shall include the following information:

28.4.1 The categories and approximate number of Client data subjects concerned;

28.4.2 The categories and approximate number of personal data records concerned;

28.4.3 The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);

28.4.4 The likely consequences of the breach;

28.4.5 Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

29. Implementation of Policy- This Policy shall be deemed effective as of 01/07/2020. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.