• Implementing procedures to comply with all relevant statutory requirements and monitoring internal procedures periodically to ensure that there is such compliance;
• Implementing and complying with the Data Protection Act 1998 (please ask for a copy of our Policy Statement in relation to Data Protection);
• Making all officers of Healthcode, its employees and subcontractors aware of the rules and procedures laid down by Healthcode from time to time in respect to the security of information and the importance of confidentiality. Officers of Healthcode, employees and sub-contractors have a duty to follow the rules laid down by Healthcode and to co-operate with Healthcode to ensure that this policy is effective. Healthcode will where it considers it appropriate take disciplinary action against any officer or employee who fails to comply with these rules and procedures;
• Taking measures to ensure the proper training, supervision and instruction of employees dealing with confidential information relating to customers;
• Requiring all subcontractors to enter into confidentiality agreements in respect to information they acquire from Healthcode;
• Establishing a committee chaired by a Healthcode director to review confidentiality and security arrangements on a regular basis and to put in place measures to maintain and, where possible, improve information security.

It is Healthcode's policy to follow the Code of practice for information security management systems set out in British Standard 7799.

Healthcode is owned jointly by BUPA, Norwich Union, Nuffield Hospitals, PPP AXA healthcare, Standard Life Healthcare and First Assist and is aware of the sensitivities of customers who may be competitors of all or any of such companies. The directors of Healthcode, whether they are employees or officers of competitor companies or not, are aware that any information they acquire in their capacity as Healthcode directors must only be used for the purposes of Healthcode supplying services to its customers and not disclosed or used for any other purpose to the detriment of Healthcode's customers.