We are committed to a policy of protecting the rights and privacy of individuals. We need to collect and use certain types of Data in order to carry on our work of managing Radford Semele Community Hall (RSCH). This personal information must 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 can be held on computers, laptops and mobile devices, or in a manual file, and includes email, minutes of meetings, and photographs. The Management Committee will remain the data controller for the information held. The trustees, staff and volunteers are personally responsible for processing and using personal information in accordance with the Data Protection Act and GDPR. Trustees, staff and volunteers 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 RSCH Management Committee’s 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 RSCH 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 – RSCH Management Committee are not required to have a DPO.
Data Subject – the individual whose personal information is being held or processed by RSCH, for example a donor or hirer.
‘Explicit’ consent – is a freely given, specific agreement by a Data Subject to the processing of personal information about her/him. Explicit consent is needed for processing “sensitive data”, which includes:
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.
RSCH Management Committee will only use Data Subject details which are disclosed for the purpose of bookings and any attendant correspondence.
Details will never be shared with any third party without specific consent. The only exception to this is in extreme case of emergency to save life, or protect from harm.
The Data Protection Act
This contains 8 principles for processing personal data with which we must comply.
We will let people know why we are collecting their data, which is for the purpose of managing the hall, its hiring and finances. It is our responsibility to ensure the data is only used for this purpose. Access to personal information will be limited to trustees and committee members.
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.
RSCH Management Committee 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 take into account legal requirements and ensure that it is properly implemented, and will through appropriate management, strict application of criteria and controls:
a) Collect and use information fairly.
b) Specify the purposes for which information is used.
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. These include:
f) Take appropriate technical and organisational security measures to safeguard personal information,
g) Ensure that personal information is not transferred abroad without suitable safeguards,
h) Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information,
i) Set out clear procedures for responding to requests for information. (See Complaints or Communications Policy) All trustees and committee members are aware that a breach of the rules and procedures identified in this policy may lead to action being taken against them.
The Booking Officer primarily deals with the Data requested for bookings.
The RSCH Management Committee will be responsible for ensuring that the policy is implemented and will have overall responsibility for:
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 a committee member
RSCH Management Committee has a duty to ensure that appropriate technical and organisational measures and training are taken to prevent:
All trustees and committee members must therefore ensure that personal data is dealt with properly no matter how it is collected, recorded or used. This applies whether or not 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.
RSCH Management Committee uses personal data for the purposes of managing the Hall, it’s bookings, finances, fund raising, running and marketing events at the Hall. Data may be retained for up to 7yrs for accounts purposes and for longer where required by the Halls insurers. Data is stored in a securely held electronic or paper file. If you would like to find out more about how your personal data is used, or want to see a copy of information about you that we hold, please contact the Booking Officer. Only the data you give us is held.
Email: All trustees, staff and volunteers should consider whether an email (both incoming and outgoing) will need to be kept as an official record. If the email needs to be retained it should be saved into the appropriate folder or printed and stored securely. Remember, emails that contain personal information no longer required for operational use, should be deleted from the personal mailbox and any “deleted items” box.
Phone Calls: Phone calls can lead to unauthorised use or disclosure of personal information and the following precautions should be taken:
Laptops and Portable Devices: All laptops and portable devices that hold data containing personal information must be protected with a suitable encryption program (password). Ensure your laptop is locked (password protected) when left unattended, even for short periods of time. When travelling in a car, make sure the laptop is out of sight, preferably in the boot. If you have to leave your laptop in an unattended vehicle at any time, put it in the boot and ensure all doors are locked and any alarm set. Never leave laptops or portable devices in your vehicle overnight. Do not leave laptops or portable devices unattended in restaurants or bars, or any other venue. When travelling on public transport, keep it with you at all times, do not leave it in luggage racks or even on the floor alongside you.
Store as little personal data as possible on your computer or laptop; only keep those files that are essential. Personal data received on disk or memory stick should be saved to the relevant file on the server or laptop. The disk or memory stick should then be securely returned (if applicable), safely stored or wiped and securely disposed of. Always lock (password protect) your computer or laptop when left unattended. Passwords: Do not use passwords that are easy to guess. All your passwords should contain both upper and lower-case letters and preferably contain some numbers. Ideally passwords should be 6 characters or more in length.
Protect Your Password: Common sense rules for passwords are:
Personal data will be stored securely and will only be accessible to authorised trustees and committee members. Information will be stored for only as long as it is needed or required by statute and will be disposed of appropriately. For financial records this will be up to 7 years. 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 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.
Use bcc if emails have to be copied wider than Management Committee
This will be checked regularly. Any page which has been completed will be removed, appropriate action taken and the page filed securely.
Personal Data should be anonymous if disputes have to be minuted
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:
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, staff and volunteers 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.
Adopted by committee:
Date June 2021
Last reviewed: January 2022
Next Review: January 2023
Signed: P Follett Chairperson
Once Committee Members have read and understood the Policy they have had ‘basic training’.