Do You Need to Appoint a Data Protection Officer for GDPR?
The ICO has determined that organisations processing special categories of data on a large scale must appoint a Data Protection Officer. Patient health data is considered a special category and during a conversation with the ICO they stated that they consider clinics with data on thousands of patients was “large scale”. If in doubt we would recommend you contact the ICO directly.
A DPO cannot be someone who is directly involved in processing the personal data, which normally means no-one employed at the clinic can be given this role.
A DPO Package Designed for Clinics
The challenge for many clinics is balancing the requirements of GDPR with the fact that they are a small organisation. So we have designed a DPO package for clinics, which we think will make appointing a DPO affordable and manageable.
We have assumed that you will have worked through the GDPR Toolkit and so will not need hours of our time doing all of this preliminary work for you. This means we can offer a DPO package that we think is affordable and designed for clinics.
- Email and phone advice on GDPR queries
- Main contact for Data Subject Access Rights requests
- Annual Visit to one site (travelling expenses charged) to include
- Review of your documentation
- Review of your GDPR policies
- Review of your GDPR procedures
- Assistance with staff education
- Independent advice and assessment of your GDPR
- Assist with Data Protection Impact Assessments
When you change your systems (change staff, purchase new software, move away from a paper based system, etc, etc) GDPR requires you to assess the impact of these changes. We will assist with this. As the work required could vary considerably we will not include this in the package but will charge separately for this service.
- Manage data breach
If you have a data breach then you will need to put into place your Data Breach Procedures. We will manage this for you. As the work required could vary considerably we will not include this in the package but will charge separately for this service.
To keep everything affordable we have three packages, based upon the size of your clinic.
Single site or 1 – 10 practitioners
£75 per month, plus VAT
Medium Sized Clinic
2 -3 sites, or 11-30 practitioners
£125 per month, plus VAT
3 sites or more than 30 practitioners
£250 per month, plus VAT