Data Protection Policy
Last Updated: January 22, 2024
1. DATA PROTECTION PRINCIPLES
The Organization is committed to processing data in accordance with its responsibilities under the Data Protection Act (DPA). The DPA requires that personal data shall be:
- Processed lawfully, fairly, and in a transparent manner in relation to individuals.
- Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
- Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
- Accurate and, where necessary, kept up to date.
- 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.
- Processed in a manner that ensures appropriate security of the personal data.
2. GENERAL PROVISIONS
This policy applies to all personal data processed by the Organization. The Responsible Person shall take responsibility for the Organization’s ongoing compliance with this policy. This policy shall be reviewed at least annually. The Organization shall register with the Information Commissioner’s Office as an organization that processes personal data.
3. LAWFUL, FAIR, AND TRANSPARENT PROCESSING
To ensure its processing of data is lawful, fair, and transparent, the Organization shall maintain a Register of Systems. Individuals have the right to access their personal data, and any such requests made to the Organization shall be dealt with in a timely manner.
4. LAWFUL PURPOSES
All data processed by the Organization must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task, or legitimate interests. The Organization shall note the appropriate lawful basis in the Register of Systems. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
5. DATA MINIMIZATION
The Organization shall ensure that personal data are adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
6. ACCURACY
The Organization shall take reasonable steps to ensure personal data is accurate. 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.
7. ARCHIVING / REMOVAL
To ensure that personal data is kept for no longer than necessary, the Organization shall put in place an archiving policy for each area in which personal data is processed and review this process annually. The archiving policy shall consider what data should/must be retained, for how long, and why.
8. SECURITY
The Organization shall ensure that personal data is stored securely using modern software that is kept up-to-date. Access to personal data shall be limited to personnel who need access, and appropriate security should be in place to avoid unauthorized sharing of information. When personal data is deleted, this should be done safely such that the data is irrecoverable. Appropriate back-up and disaster recovery solutions shall be in place.
9. BREACH
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, the Organization shall promptly assess the risk to people’s rights and freedoms and, if appropriate, report this breach to the Information Commissioner’s Office (ICO).