24th May 2018
Charity – Means VOICES Charity, as a registered Charity.
GDPR – Means the General Data Protection Regulation.
Responsible Person – Means authorised personnel responsible for data protection within the Charity.
1. Data protection principles
VOICES is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c. relevant and limited to what is needed in relation to the purposes that it is processed for;
d. accurate and, where necessary, kept up to date; reasonable steps must be taken ensuring that inaccurate data, regarding the relevance for processing, are erased or rectified;
e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes that it is processed for; personal data may be stored for longer periods insofar as the data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
2. General provisions
a. This policy applies to all personal data processed by our Charity, registered with the Information Commissioner’s Office as an organisation that processes personal data.
b. The Responsible Persons shall take responsibility for the Charity’s ongoing compliance with this policy and this policy shall be reviewed at least annually.
3. Lawful, fair and transparent processing
a. To ensure its processing of data is lawful, fair and transparent, our Charity shall maintain a Register of Systems that will be reviewed annually.
b. Individuals have the right to access their personal data and any such requests made to the Charity shall be dealt with in a timely manner.
c. All data processed by our Charity must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests which may be noted on our Register of Systems.
d. Where consent is relied upon, evidence thereof shall be kept with the personal data.
e. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent will be clearly available and systems updated as such.
4. Data minimisation and Accuracy
a. The Charity shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
b. Where necessary for the lawful basis on which data is processed, reasonable steps shall be put in place to ensure that personal data is kept accurate and up to date.
5. Archiving / removal
a. To ensure that personal data is kept for no longer than necessary, the Charity will have an archiving policy to store data in line with its purpose and review this process annually.
a. The Charity shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
b. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
c. When personal data is deleted this should be done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Charity shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).