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GDPR Policy

Small Strides CIC is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to individuals;

  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;

  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

  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 are 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 individuals; and

  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.”


General provisions

  1. This policy applies to all personal data processed by Small Strides.

  2. The Responsible Person shall take responsibility for Small Strides ongoing compliance with this policy.

  3. This policy shall be reviewed at least annually.

Lawful, fair and transparent processing

  1. Individuals have the right to access their personal data and any such requests made to Small Strides shall be dealt with in a timely manner.


Lawful purposes

  1. All data processed by the Small Strides must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests

  2. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.

  3. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the organisations systems. 


Data minimisation

  1. Small Strides CIC shall ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. The personal data we collect for our clients is used to person centre the best options for therapeutic programs for the individual based on their needs.

  2. This data will never be shared with any other individual, organisation or persons.

  3. Personal data will only be shared if requested by the individual.


  1. The Small Strides CIC shall take reasonable steps to ensure personal data is accurate.

  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.


Archiving / removal

  1. To ensure that personal data is kept for no longer than necessary, all forms with personal data on are dated and are sorted annually and any data that is no longer necessary will be shredded.


  1. All personal data held by Small Strides is stored securely in a locked filing cabinet, only the Responsible Person has access to this cabinet.

  2. When all personal data is destroyed of it is done by the responsible person and is shredded so  the data is irrecoverable.

  3. No personal data is stored on computers.

  4. Any forms that are sent via email are printed and stored away in a locked cabinet. Only the responsible person has access to this password protected email address and all emails are deleted after data has been printed and filed away.



In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Small Strides CIC shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO.

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