GDPR: Privacy Information Notice
How We Keep Your Information Safe
TBS is committed to a policy of protecting the rights and privacy of individuals, including members, volunteers, staff and others, in accordance with the General Data Protection Regulation (GDPR) May 2018.
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What personal information do we collect?
Personal information is any information that can be used to identify you. This information may include your name, e-mail address, postal address, contact numbers, date of birth, financial details, UK Tax payer information (for Gift Aid), as well as how you came to find us or about our service or events. If appropriate, we may also keep details of safeguarding issues, medical information and criminal convictions. We may collect this information in paper application forms or electronically via e-mail.
We may also collect details of your visits to our website, such as your location data and other website related information. For further details, please refer to our cookies policy which you will find at the top of our home page on our website (www.thebefriendingscheme.org.uk)
Keeping your information up to date
We need to make sure that we always have the most up-to-date information about how to contact you so we may, from time to time, contact you to check the details we hold are still correct.
We will review and update all data on a regular basis. It is the responsibility of the individuals giving their personal data to ensure that this is accurate, and each individual should notify TBS if, for example, a change in circumstances mean that the data needs to be updated. It is the responsibility of TBS to ensure that any notification regarding the change is noted and acted on.
How do we store your information?
We have put appropriate technical and organisational measures in place against unauthorised or unlawful processing of personal data, and against accidental loss or destruction of data.
All members of staff are responsible for ensuring that any personal data which they hold is kept securely and not disclosed to any unauthorised third parties. We will ensure that all personal data is accessible only to those who have a valid reason for using it. We have in place appropriate security measures e.g. ensuring that hard copy personal data is kept in lockable filing cabinets/cupboards with controlled access (with the keys then held securely in a key cabinet with controlled access):
- keeping all personal data in a lockable cabinet with key-controlled access.
- password protecting personal data held electronically.
- archiving personal data which are then kept securely (lockable cabinet).
- placing any PCs or terminals, CCTV camera screens etc. that show personal data so that they are not visible except to authorised staff.
- ensuring that PC screens are not left unattended without a password protected screen-saver being used.
In addition, we have put in place appropriate measures for the deletion of personal data - manual records will be shredded or disposed of as ‘confidential waste’ and appropriate contract terms will be put in place with any third parties undertaking this work. Hard drives of redundant PCs will be wiped clean before disposal or if that is not possible, destroyed physically. A log will be kept of the records destroyed. This policy also applies to staff and volunteers who process personal data ‘off-site’, e.g. when working at home, and in circumstances additional care must be taken regarding the security of the data.
How will your information be used?
We may use your information externally to comply with our legal/contractual obligations in relation for providing monitoring data and evidence to funding bodies and government including local government. We also use it for means of communicating medical and/or safeguarding information internally to other staff members, as appropriate, for the safety and protection of our members and volunteers, and to assist with strategic decision making for the sustainability and future delivery of services.
TBS also needs to process certain information about its staff, members, volunteers, customers and other individuals with whom it has a relationship for various purposes such as, but not limited to:
- the administration of services
- recording individual progress and attendance on training courses
- collecting membership fees and funding
How long will we keep your information for?
We will not retain personal data for longer than is necessary to ensure compliance with the legislation, and any other statutory requirements. This means we will undertake a regular review of the information. We will dispose of any personal data in a way that protects the rights and privacy of the individual concerned (e.g. secure electronic deletion, shredding and disposal of hard copy files as confidential waste). A log will be kept of the records destroyed
To comply with various legal obligations, including the obligations imposed on it by the General Data Protection Regulation (GDPR) TBS must ensure that all this information about individuals is collected and used fairly, stored safely and securely, and not disclosed to any third party unlawfully.
This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments to the GDPR and other relevant legislation.
Responsibilities under the GDPR
TBS is the ‘data controller’ under the terms of the legislation – this means it is ultimately responsible for controlling the use and processing of the personal data. TBS has appointed a Data Protection Officer (DPO) - currently the Operations Manager - who is available to address any concerns regarding the data held by TBS and how it is processed, held and used.
The Senior Leadership Team is responsible for all day-to-day data protection matters, and will be responsible for ensuring that all members of staff and relevant individuals abide by this policy, and for developing and encouraging good information handling within the organisation.
Details of TBS’s notification can be found on the Office of the Information Commissioner’s website. Our data registration number is: ZA150156 The Senior Leadership Team is also responsible for ensuring that TBS’s notification is kept accurate
Compliance with the legislation is the personal responsibility of all members of TBS who process personal information. Individuals who provide personal data to TBS are responsible for ensuring that the information is accurate and up-to-date.
Data Protection Principles
The legislation places a responsibility on every data controller to process any personal data in accordance with data protection principles. More detailed guidance on how to comply with these principles can be found in the DPCoP. Please follow this link to the ICO’s website (www.ico.gov.uk) In order to comply with its obligations, TBS undertakes to adhere to the eight principles:
1) Process personal data fairly and lawfully.
TBS will make all reasonable efforts to ensure that individuals who are the focus of the personal data (data subjects) are informed of the identity of the data controller, the purposes of the processing, any disclosures to third parties that are envisaged; given an indication of the period for which the data will be kept, and any other information which may be relevant.
2) Process the data for the specific and lawful purpose for which it collected that data and not further process the data in a manner incompatible with this purpose.
TBS will ensure that the reason for which it collected the data originally is the only reason for which it processes those data, unless the individual is informed of any additional processing before it takes place.
3) Ensure that the data is adequate, relevant and not excessive in relation to the purpose for which it is processed.
TBS will not seek to collect any personal data which is not strictly necessary for the purpose for which it was obtained. Forms for collecting data will always be drafted with this mind. If any irrelevant data are given by individuals, they will be destroyed immediately.
4) Process personal data in accordance with the rights of the data subject under the legislation.
Individuals have various rights under the legislation including a right to:
- be told the nature of the information TBS holds and any parties to whom this may be disclosed.
- prevent processing likely to cause damage or distress.
- prevent processing for purposes of direct marketing.
- be informed about the mechanics of any automated decision taking process that will significantly affect them.
- not have significant decisions that will affect them taken solely by automated process.
- sue for compensation if they suffer damage by any contravention of the legislation.
- take action to rectify, block, erase or destroy inaccurate data.
- request that the Office of the Information Commissioner assess whether any provision of the Act has been contravened.
TBS will only process personal data in accordance with individuals’ rights.
5) Ensure that no personal data is transferred to a country or a territory outside the European Economic Area (EEA) unless that country or territory ensures adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
TBS will not transfer data to such territories without the explicit consent of the individual. This also applies to publishing information on the Internet - because transfer of data can include placing data on a website that can be accessed from outside the EEA - so TBS will always seek the consent of individuals before placing any personal data (including photographs) on its website. If TBS collects personal data in any form via its website, it will provide a clear and detailed privacy statement prominently on the website, and wherever else personal data is collected.
TBS will ensure that any forms used to gather data on an individual will contain a statement (fair collection statement) explaining the use of that data, how the data may be disclosed and also indicate whether or not the individual needs to consent to the processing.
TBS will ensure that if the individual does not give his/her consent for the processing, and there is no other lawful basis on which to process the data, then steps will be taken to ensure that processing of that data does not take place.
Subject Access Rights (SARs)
Individuals have a right to access any personal data relating to them which are held by TBS. Any individual wishing to exercise this right should apply in writing to the Chief Executive. Any member of staff receiving a SAR should forward this to the Chief Executive. TBS reserves the right to charge a fee for data subject access requests (currently £20). Under the terms of the legislation, any such requests must be complied with within 40 days.
Disclosure of Data
Only disclosures which have been notified under TBSs DP notification must be made and therefore staff should exercise caution when asked to disclose personal data held on another individual or third party.
TBS undertakes not to disclose personal data to unauthorised third parties, including family members, friends, government bodies and in some circumstances, the police. Legitimate disclosures may occur in the following instances:
- the individual has given their consent to the disclosure.
- the disclosure is in the legitimate interests of the individual.
- the disclosure is required for the performance of a contract.
There are other instances when the legislation permits disclosure without the consent of the individual.
In no circumstances will TBS sell any of its databases to a third party.
Publication of TBS’s Information
TBS publishes various items which will include some personal data, e.g.
- internal telephone directory.
- event information.
- photos and information in marketing materials.
It may be that in some circumstances an individual wishes their data processed for such reasons to be kept confidential, or restricted organisation access only.
Therefore, it is TBS policy to offer an opportunity to opt-out of the publication of such when collecting the information.
It is the policy of TBS to ensure that senders and recipients of email are made aware that under the DPA, and Freedom of Information Legislation, the contents of email may have to be disclosed in response to a request for information. One means by which this will be communicated will be by a disclaimer on TBS’s email.
Under the Regulation of Investigatory Powers Act 2000, Lawful Business Practice Regulations, any email sent to or from TBS may be accessed by someone other than the recipient for system management and security purposes.
There are some CCTV systems operating within TBS for the purpose of protecting its members and property. TBS will only process personal data obtained by the CCTV system in a manner which ensures compliance with the legislation.
Procedure for review
This policy will be updated as necessary to reflect best practice or future amendments made to the General Data Protection Regulation (GDPR) May 2018 and Data Protection Act 1998. Please follow this link to the ICO’s website (www.ico.gov.uk) which provides further detailed guidance on a range of topics including individuals’ rights, exemptions from the Act, dealing with subject access requests, how to handle requests from third parties for personal data to be disclosed etc. In particular, you may find it helpful to read the Guide to Data Protection which is available from the website.
For help or advice on any data protection or freedom of information issues, please do not hesitate to contact: The Data Protection Officer (DPO)