Privacy & Data Protection
The Keene Hall has set out below its Data Protection Policy.
Any queries should be raised with: firstname.lastname@example.org in the first instance.
The Keene Hall
(Registered Charity No. 282025)
General Data Protection Regulations - Data Protection Policy
We are committed to a policy of protecting the rights and privacy of individuals. We need to collect and use certain types of data to carry on our work of managing the Keene Hall. This personal information will be collected and handled securely.
The Data Protection Act 1998 (DPA) and General Data Protection Regulations (GDPR) govern the use of information about people (personal data). Personal data (PD) can be held on computers, laptops and mobile devices, or in a manual file, and includes email, minutes of meetings, and photographs.
The charity will remain the data controller for the information held. The trustees and staff are personally responsible for processing and using personal information in accordance with the Data Protection Act and GDPR. Trustees and staff who have access to personal information will therefore be expected to read and comply with this policy.
The purpose of this policy is to set out the Keene Hall commitment and procedures for protecting personal data. Trustees regard the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal. We recognise the risks to individuals of identity theft and financial loss if personal data is lost or stolen.
The following are definitions of the terms used:
Data Controller - the trustees who collectively decide what personal information the Keene Hall will hold and how it will be held or used.
‘Act’ means the Data Protection Act 1998 and General Data Protection Regulations - the legislation that requires responsible behaviour by those using personal information.
Data Protection Officer – the person responsible for ensuring that the Keene Hall follows its data protection policy and complies with the Act. [The Keene Hall is not required to appoint a DPO].
Data Subject – the individual whose personal information is being held or processed by the Keene Hall for example a donor or hirer.
Information Commissioner’s Office (ICO) - the ICO is responsible for implementing and overseeing the Data Protection Act 1998.
Processing – means collecting, amending, handling, storing or disclosing personal information.
Personal Information – information about living individuals that enables them to be identified – e.g. names, addresses, telephone numbers and email addresses. It does not apply to information about organisations, companies and agencies but applies to named persons, such as individual volunteers.
The Data Protection Act
This contains eight principles for processing personal data with which we will comply.
- Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met,
- Shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes,
- Shall be adequate, relevant and not excessive in relation to those purpose(s).
- Shall be accurate and, where necessary, kept up to date,
- Shall not be kept for longer than is necessary,
- Shall be processed in accordance with the rights of data subjects under the Act,
- Shall be kept secure by the Data Controller, who takes appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal information,
- Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal information.
Applying the Data Protection Act within the charity
We will let people know why we are collecting their data, which is for managing the hall, its hirings and finances and staff employment. It is our responsibility to ensure the data is only used for these purposes. Access to personal information will be limited to trustees and staff.
Individuals have a right to make a Subject Access Request (SAR) to find out whether the charity holds their personal data, where, what it is used for and to have data corrected if it is wrong, to prevent use which is causing them damage or distress, or to stop marketing information being sent to them. Any SAR must be dealt with within 30 days. Steps must first be taken to confirm the identity of the individual before providing information, requiring both photo identification e.g. passport and confirmation of address e.g. recent utility bill, bank or credit card statement. The Keene Hall will deal with any SAR within 30 days in accordance with ICO guidance currently prevailing.
The Keene Hall is the Data Controller under the Act, and is legally responsible for complying with Act, which means that it determines what purposes personal information held will be used for.
The management committee will consider legal requirements and ensure that it is properly implemented, and will through appropriate management, apply strict application of criteria and controls:
a) Collect and use information fairly.
b) Specify the purposes for which information is used (managing the hall, its finances and hirings).
c) Collect and process appropriate information, and only to the extent that it is needed to fulfil its operational needs or to comply with any legal requirements.
d) Ensure the quality of information used.
e) Ensure the rights of people about whom information is held, can be exercised under the Act.
- The right to be informed that processing is undertaken.
- The right of access to one’s personal information.
- The right to prevent processing in certain circumstances, and
- The right to correct, rectify, block or erase information, which is regarded as wrong information.
- Take appropriate technical and organisational security measures to safeguard personal information,
- Ensure that personal information is not transferred abroad without suitable safeguards,
- Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information,
- All trustees and staff are aware that a breach of the rules and procedures identified in this policy may lead to action being taken against them.
The Keene Hall Trustees’ will be responsible for ensuring that the policy is implemented and will have overall responsibility for:
a) Everyone processing personal information understands that they are contractually responsible for following good data protection practice
b) Everyone processing personal information is appropriately trained to do so
c) Everyone processing personal information is appropriately supervised
d) Anybody wanting to make enquiries about handling personal information knows what to do
e) Dealing promptly and courteously with any enquiries about handling personal information
f) Describe clearly how the charity handles personal information
g) Will annually review and audit the ways it holds, manages and uses personal information
h) Will regularly assess and evaluate its methods and performance in relation to handling personal information.
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 made to the Data Protection Act 1998.
In case of any queries or questions in relation to this policy, please contact the Administrator, Keene Hall
Procedures for Handling Data & Data Security
The Keene Hall has a duty to ensure that appropriate technical and organisational measures and training are taken to prevent:
- Unauthorised or unlawful processing of personal data
- Unauthorised disclosure of personal data
- Accidental loss of personal data
All trustees and staff must therefore ensure that personal data is dealt with properly no matter how it is collected, recorded or used. This applies whether the information is held on paper, in a computer or recorded by some other means e.g. tablet or mobile phone.
Personal data relates to data of living individuals who can be identified from that data and use of that data could cause an individual damage or distress. This does not mean that mentioning someone’s name in a document comprises personal data; however, combining various data elements such as a person’s name and salary or religious beliefs etc. would be classed as personal data, and falls within the scope of the DPA.
It is therefore important that all staff consider any information (which is not otherwise in the public domain) that can be used to identify an individual as personal data and observe the guidance given below.
Personal data will be stored securely and will only be accessible to authorised trustees or staff.
Information will be stored for only if it is needed or required by statute and will be disposed of appropriately. For financial records this will be up to 7 years. For employee records see below. Archival material such as minutes and legal documents will be stored indefinitely. Other correspondence and emails will be disposed of when no longer required or when trustees, staff or volunteers retire.
All personal data held for the organisation must be non-recoverable from any computer, or other storage device, which has been passed on/sold to a third party.
Information Regarding Employees or Former Employees:
Information regarding an employee or a former employee, will be kept indefinitely. If something occurs years later it might be necessary to refer to a job application or other document to check what was disclosed earlier, in order that trustees comply with their obligations e.g. regarding employment law, taxation, pensions or insurance.
This will be checked regularly. Any page which has been completed will be removed, appropriate action taken, and the page filed securely.
Data Subject Access Requests:
We may occasionally need to share data with other agencies such as the local authority, funding bodies and other voluntary agencies in circumstances which are not in furtherance of the management of the charity. The circumstances where the law allows the charity to disclose data (including sensitive data) without the data subject’s consent are:
a) Carrying out a legal duty or as authorised by the Secretary of State
b) Protecting vital interests of a Data Subject or other person e.g. child protection
c) The Data Subject has already made the information public
d) Conducting any legal proceedings, obtaining legal advice or defending any legal rights
e) Monitoring for equal opportunities purposes – i.e. race, disability or religion
We regard the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal
Personal Data and third parties
We intend to ensure that personal information, or data, is treated lawfully and correctly and is NOT passed on to third parties, unless there is a legal requirement to do so.
The consequences of breaching Data Protection can cause harm or distress to service users if their information is released to inappropriate people, or they could be denied a service to which they are entitled.
Trustees and staff should be aware that they can be personally liable if they use customers’ personal data inappropriately. This policy is designed to minimise the risks and to ensure that the reputation of the charity is not damaged through inappropriate or unauthorised access and sharing.
This policy statement was agreed by the Board of Trustees at a meeting held on 29th May 2018
Susan Royce (Mrs), Administrator, the Keene Hall