The HIV Resistance Response Database Initiative (RDI) regards the lawful and correct treatment of personal information as very important. We will ensure that we treat personal information lawfully and correctly. To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).
This policy applies to the processing of personal data in manual and electronic records kept by us in connection with our human resources function, our research and our collaborations with others in the medical research field.
“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.
“Special categories of personal data” is data which relates to an identifiable individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).
“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity.
All of the above information is required for the fulfilment of our employment contracts. More information on those processing activities are included in our privacy notice for employees, which is available from your manager.
because of one of more of the following legitimate interests:
The RDI receives data relating to hundreds of thousands of HIV patients from hospitals, research centres, cohorts and clinical trials all over the world. The data are stripped of all identifiers, completely anonymous and are therefore not considered personal data.
The RDI uses these data in order to develop computational models to predict how patients will respond to any combination of HIV drugs. These models are available as a free treatment support tool via the RDI web site. The data consist of some or all of the following for each patient:
The institutions providing these data have the right to withdraw their data at any point.
Employees, consultants, collaborators and other professionals in the HIV field all have a right to access any personal data that we hold on them. To exercise this right, they should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.
The Company may be required to disclose certain data/information on employees to any person. The circumstances leading to such disclosures include:
These kinds of disclosures will only be made when strictly necessary for the purpose.
All our employees are aware that hard copy personal information should be kept in a locked filing cabinet, drawer, or safe. Employees are aware of their roles and responsibilities when processing data. All employees are instructed to store files or written information of a confidential nature in a secure manner so that are only accessed by people who have a need and a right to access them and to ensure that screen locks are implemented on all PCs, laptops etc when unattended. No files or written information of a confidential nature are to be left where they can be read by unauthorised people.
Where data is computerised, it should be coded, encrypted or password protected both on a local hard drive and on a network drive that is regularly backed up. If a copy is kept on removable storage media, those media must be kept in a locked filing cabinet, drawer, or safe.
Employees must always use the passwords provided to access the computer system and not abuse them by passing them on to people who should not have them.
Personal data relating to employees should not be kept or transported on laptops, USB sticks, or similar devices, unless prior authorisation has been received. Where personal data is recorded on any such device it should be protected by:
Failure to follow the Company’s rules on data security may be dealt with via the Company’s disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.
Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data.
The Company does not transfer personal data to any recipients outside of the EEA.
All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.
New employees must read and understand the policies on data protection as part of their induction.
All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach. The nominated data controller for the Company is trained appropriately in their role under the GDPR.
All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and the Company of any potential lapses and breaches of the Company’s policies and procedures.
The Company keeps records of its processing activities including the purpose for the processing and retention periods in its Data Protection Record. These records will be kept up to date so that they reflect current processing activities.
Our appointed compliance officer is:
+44 20 226 7314
© 2003-2019 RDI - All Rights Reserved - Updated 21st May 2018