Data Protection and Privacy Policy

Table of Contents

Document History & Version Control

Version Description of Revision Prepared / Reviewed by Approved by Date Approved Next Review Date
1.2 Policy based on Indian IT Act Niraj Desai Mukund Malani 01/04/2021 31/03/2025
2.0 Major revision to comply with Bahrain PDPL (Law 30 of 2018). Added DPO, Data Subject Rights, Cross-Border Transfer rules, Lawful Bases, and Breach Notification. [Name] [Name] [Date] [Date + 1 Year]

1. Objective

The aim of this policy is to ensure that Tasheel Healthcare handles all personal data in full compliance with Bahrain's Personal Data Protection Law (PDPL), Law No. (30) of 2018, and that everyone processing such data is aware of and adheres to the required data protection procedures.

2. Scope

This policy applies to all staff employees, business partners, implementers, consultants, and any third parties processing personal data on behalf of Tasheel Healthcare.

3. Overview

Bahrain's Personal Data Protection Law (PDPL), Law No. (30) of 2018, mandates the secure, fair, and lawful processing of personal information. Tasheel Healthcare processes personal data of clients, business partners, and employees to carry out its operations and comply with legal obligations.

The organization is committed to ensuring that all personal data is processed in line with the PDPL. Information will be collected and used fairly, stored safely, and not disclosed unlawfully.

Definitions

Personal Data: Any data relating to an identified or identifiable natural person.

Sensitive Personal Data: Includes data related to children, health, genetics, biometrics, beliefs, and offences.

Processing: Any operation performed on Personal Data (e.g. collection, storage, disclosure, deletion).

Data Subject: The natural person to whom the Personal Data relates.

Data Protection Officer (DPO): Responsible for overseeing compliance with data protection laws.

Core Principles of Data Processing

3.1 Type of Information Processed

Tasheel Healthcare processes information such as name, contact details, designation, company, financial data, and sensitive personal data with explicit consent.

4. Policy

4.1 General Provisions

Tasheel Healthcare, as the Data Controller, is responsible for the distribution and access to personal data, delegating day-to-day matters to the DPO.

4.2 Implementation

We ensure personal data is collected lawfully, used fairly, stored securely, and rights of data subjects are respected.

4.3 Training

All employees receive training on data protection during induction and regular awareness programs.

4.4 Collection of Personal Data

We collect only necessary information for legitimate business purposes.

4.5 Lawful Bases and Purposes of Processing

4.6 Limited Access

Only authorized individuals have access to personal data, based on necessity.

4.7 Disclosure and Transfer of Personal Data

Data may be disclosed to group companies, auditors, banks, third-party processors, or regulators as required.

4.8 Cross-Border Data Transfer

Transfers outside Bahrain are made only under PDPL-compliant conditions such as adequate protection or explicit consent.

4.9 Retention and Deletion

Data is retained only as long as necessary and securely deleted thereafter.

4.10 Security

Appropriate security measures including encryption, access control, and secure storage are applied.

4.11 Accuracy

Data subjects are responsible for notifying changes to ensure accuracy.

4.12 Data Subject Rights

4.13 Data Breach Notification

Breaches are reported to the PDPA within 72 hours and to data subjects when high risk exists.

5. Responsibility & Authority

Top management is responsible; the DPO oversees compliance, training, and acts as contact for the authority.

6. Communication of Policy

This policy is shared with employees, partners, and published on the website.

7. Review

Reviewed annually by the DPO and related teams to ensure effectiveness.

8. Violations

Non-compliance may result in disciplinary action, up to termination as per HR Security Policy.

9. References