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Privacy Policy
Data Protection Policy
Overview of the General Data Protection Regulation
Women of Newport will ensure that all personal data that it holds will be:
● processed lawfully, fairly and in a transparent manner;
● 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;
● accurate and kept up to date;
● kept in a form which permits identification of data subjects for no longer than is necessary;
● 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.
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Data Protection Policy
1. Introduction to the UK-GDPR
Under the United Kingdom General Data Protection Regulations (UKGDPR) Our Chartist Heritage (WOMEN OF NEWPORT) is required to comply with the UK-GDPR and undertakes to do so. Throughout this policy document, numbers prefixed by “Art:“ in brackets (eg: {Art:5}) refer to the relevant Article(s) in the UK-GDPR, as modified by the Keeling Schedule.
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/969514/20201102_-_GDPR_-__MASTER__Keeling_Schedule__with_changes_highlighted__V4.pdf
2. Definitions
The definitions of terms used in this policy are the same as the definitions of those same terms detailed in Article-4 of the UK-GDPR.
Data Subject
A data subject is an identifiable individual person about whom WOMEN OF NEWPORT holds personal data.
Contact Information
For the purposes of this policy, contact information means any or all of the person’s:
· full name (including any preferences about how they like to be called)
· full postal address
· telephone and/or mobile number(s)
· e-mail address(es)
· social media IDs/usernames (eg: Facebook, Skype, Hangouts, WhatsApp)
3. Principles of the UK-GDPR
WOMEN OF NEWPORT will ensure that all personal data that it holds will be:
a) processed lawfully, fairly and in a transparent manner in relation to individuals
b) collected only 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) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e) kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
personal data may be stored for longer periods insofar as the personal 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 UK-GDPR in order to safeguard the rights and freedoms of individuals
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.
4. Lawful Processing
WOMEN OF NEWPORT will obtain, hold and process all personal data in accordance with the UK-GDPR for the following lawful purposes. In all cases the information collected, held and processed will include contact information (as defined in 2 above).
5. By Consent
People who are interested in, and wish to be kept informed of, the activities of WOMEN OF NEWPORT.
a) Subject to the person’s consent, this may include information selected and forwarded by WOMEN OF NEWPORT on activities by other organisations which are relevant to those of WOMEN OF NEWPORT
Note: this will never involve providing the person’s personal data to another organisation.
b) The information collected may additionally contain details of any particular areas of interest about which the person wishes to be kept informed.
c) The information provided will be held and processed solely for the purpose of providing the information requested by the person.
6. By Contract
People who sell goods and/or services to, and/or purchase goods and/or services from WOMEN OF NEWPORT.
The information collected will additionally contain details of:
a) The goods/services being sold to, or purchased from WOMEN OF NEWPORT;
b) Bank and other details necessary and relevant to the making or receiving of payments for the goods/services being sold to, or purchased from WOMEN OF NEWPORT.
The information provided will be held and processed solely for the purpose of managing the contract between WOMEN OF NEWPORT and the person for the supply or purchase of goods/services.
7. By Legal Obligation
WOMEN OF NEWPORT currently undertakes no activities, such as employing paid staff, that place it under a legal obligation to collect, process and share information with a third party.
8. By Vital Interest
WOMEN OF NEWPORT undertakes no activities that require the collection, holding and/or processing of personal information for reasons of vital interest.
9. By Public Task
WOMEN OF NEWPORT undertakes no public tasks that require the collection, holding and/or processing of personal information.
10. Legitimate Interest
Volunteers, including trustees In order to be able to operate efficiently, effectively and economically, it is in the legitimate interests of WOMEN OF NEWPORT to hold such personal information on its volunteers and trustees as will enable WOMEN OF NEWPORT to communicate with its volunteers on operational matters such as:
· the holding of meetings;
· providing information about WOMEN OF NEWPORT’s activities – particularly those activities which, by their nature, are likely to be of particular interest to individual volunteers/trustees;
· seeking help, support and advice from volunteers/trustees, particularly where they have specific knowledge and experience;
· ensuring that any particular needs of the volunteer/trustee are appropriately and sensitively accommodated when organising meetings and other activities of WOMEN OF NEWPORT
11. Closed Circuit TV (CCTV) Recording
WOMEN OF NEWPORT does not currently own or occupy premises.
12. Individual Rights
Note: The following clauses are taken primarily from the guidance provided by the Office of the Information Commissioner,
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-be-informed/
13. The right to be informed
When collecting personal information WOMEN OF NEWPORT will provide to the data subject, free of charge, a Privacy Policy written in clear and plain language which is concise, transparent, intelligible and easily accessible containing the following information:
· Identity and contact details of the data controller
· Purpose of the processing and the lawful basis for the processing
· The legitimate interests of the controller or third party, where applicable
· Categories of personal data; not applicable if the data are obtained directly from the data subject
· Any recipient or categories of recipients of the personal data
· Details of transfers to third country and safeguards
· Retention period or criteria used to determine the retention period
· The existence of each of data subject’s rights
· The right to withdraw consent at any time, where relevant
· The right to lodge a complaint with a supervisory authority
· The source the personal data originates from and whether it came from publicly accessible sources; not applicable if the data are obtained directly from the data subject
· Whether the provision of personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data; not applicable if the data are NOT obtained directly from the data subject
· The existence of automated decision making, including profiling and information about how decisions are made, the significance and theconsequences.
In the case of data obtained directly from the data subject, the information will be provided at the time the data are obtained.
In the case that the data are not obtained directly from the data subject:
· the information will be provided within a reasonable period of WOMEN OF NEWPORT having obtained the data (within one month), or
· if the data are used to communicate with the data subject, at the latest, when the first communication takes place; or
· if disclosure to another recipient is envisaged, at the latest, before the data are disclosed.
14. The right of access
The data subject shall have the right to obtain from the controller confirmation as to whether or not their personal data concerning are being processed, and, where that is the case, access to their personal data and the information detailed in WOMEN OF NEWPORT’s relevant Privacy Policy:
15. The right to rectification
The data subject shall have the right to require the controller without undue delay to rectify any inaccurate or incomplete personal data concerning them.
16. The right to erase (The right to be forgotten)
Except where the data are held for purposes of legal obligation or public task (4.3 or 4.5) the data subject shall have the right to require the controller without undue delay to erase any personal data concerning them. Note: This provision is also known as “The right to be forgotten”.
17. The right to restrict processing
Where there is a dispute between the data subject and the controller about the accuracy, validity or legality of data held by WOMEN OF NEWPORT, the data subject shall have the right to require the controller to cease processing the data for a reasonable period of time to allow the dispute to be resolved.
18. The right to data portability
Where data are held for purposes of consent or contract (4.1 or 4.2) the data subject shall have the right to require the controller to provide them with a copy in a structured, commonly used and machine-readable format of the data which the data subject has provided to the controller, and shall have the right to transmit those data to another controller without hindrance.
19. The right to object (see Art 21)
a) The data subject shall have the right to object, on grounds relating to their particular situation, at any time, to processing of personal data concerning them which is based on Public Task or Legitimate Interest (4.5 or 4.6), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
b) Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning them for such marketing, which includes profiling to the extent that it is related to such direct marketing.
c) Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
d) At the latest at the time of the first communication with the data subject, the rights referred to in paragraphs a) and d) shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
20. Rights in relation to automated decision making and profiling (see Art 22)
Except where it is: a) based on the data subject’s explicit consent, or b) necessary for entering into, or performance of, a contract between the data subject and a data controller; the data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him/her or similarly significantly affects him/her.
Operational Policies and Procedures
21. Operational Policies & Procedures – The Context
WOMEN OF NEWPORT is a small charity holding just a small amount of non-sensitive data on a small number of people. The trustees understand and accept their responsibility under the UK General Data Protection Regulation (UK-GDPR) to hold all personal data securely and use it only for legitimate purposes with the knowledge and approval of the data subjects.
By the following operational policies and procedures the trustees undertake to uphold the principles and requirements of the UK-GDPR in a manner which is proportionate to the nature of the personal data being held by WOMEN OF NEWPORT. The policies are based on the trustees’ assessment, in good faith, of the potential impact on both WOMEN OF NEWPORT and its data subjects of the personal data held by the WOMEN OF NEWPORT being stolen, abused, corrupted or lost.
22. Personnel
Chairperson, Treasurer, Secretary and 2 ordinary Board members
23. Data Protection Officer
In the considered opinion of the Trustees the scope and nature of the personal data held by WOMEN OF NEWPORT is not sufficient to warrant the appointment of a Data Protection Officer. Accordingly, no Data Protection Officer is appointed.
24. Data Controller
The Board of Trustees is the Data Controller for WOMEN OF NEWPORT.
25. Data Processor
The Board of Trustees will appoint at least two and not more than five of its number, or other appropriate persons, to be the Data Processors for WOMEN OF NEWPORT. WOMEN OF NEWPORT will not knowingly outsource its data processing to any third party (eg: Google G-Suite, Microsoft OneDrive) except as provided for in the section “Third Party Access to Data”.
26. Access to Data
Except where necessary to pursue the legitimate purposes of WOMEN OF NEWPORT, only the Data Processors shall have access to the personal data held by WOMEN OF NEWPORT.
27. Training
The Board of Trustees and Data Processors will periodically undergo appropriate training commensurate with the scale and nature of the personal data that WOMEN OF NEWPORT holds and processes under the UK-GDPR.
28. Collecting & Processing Personal Data
WOMEN OF NEWPORT collects a variety of personal data commensurate with the variety of purposes for which the data are required in the pursuit of its charitable objects. All personal data will be collected, held and processed in accordance with the relevant Data Privacy Notice provided to data subjects as part of the process of collecting the data. A Data Privacy Notice will be provided, or otherwise made accessible, to all persons on whom WOMEN OF NEWPORT collects, holds and processes data covered by the UK-GDPR. The\Data Privacy Notice provided to data subjects will detail the nature of the data being\collected, the purpose(s) for which the data are being collected and the subject’s\rights in relation to WOMEN OF NEWPORT’s use of the data and other relevant information in\compliance with the prevailing UK-GDPR requirements.
29. Information Technology
n/a
30. Data Protection by Design/Default
Inasmuch as:
a) none of WOMEN OF NEWPORT’s volunteer trustees are data protection professionals; and
b) it would be a disproportionate use of community funds to employ a data protection professional, given the scale and nature of the personal data held by WOMEN OF NEWPORT; the trustees will seek appropriate professional advice commensurate with its data protection requirement whenever:
c) they are planning to make significant changes to the ways in which they process personal data;
d) there is any national publicity about new risks (eg: cyber attacks);
e) any material changes to the UK-GDPR are proposed or have been made which might adversely compromise WOMEN OF NEWPORT’s legitimate processing of personal data covered by the UK-GDPR.
31. Data Processing Equipment
The scale and nature of the personal data held by WOMEN OF NEWPORT is not sufficient to justify WOMEN OF NEWPORT purchasing dedicated computers for the processing of personal data.
32. Data Backups
To protect against loss of data by accidental corruption of the data or malfunction of a removable data storage device (including by physical damage), all the community group’s personal data shall be backed up periodically and whenever any significant changes (additions, amendments, deletions) are made to the data.
33. Obsolete or Dysfunctional Equipment
Equipment used to hold personal data, whether permanently or as interim working copies, which come to the end of their useful working life, or become dysfunctional, shall be disposed of in a manner which ensures that any residual personal data held on the equipment cannot be recovered by unauthorised persons.
Inasmuch as:
a) this will be a relatively infrequent occurrence;
b) techniques for data recovery and destruction are constantly evolving;
c) none of the trustees has relevant up-to-date expert knowledge of data cleansing;
34. The Rights of Data Subjects
In compliance with the UK-GDPR WOMEN OF NEWPORT will give data subjects the following rights. These rights will be made clear in the relevant Data Privacy Notice provided to data subjects:
· the right to be informed;
· the right of access;
· the right to rectification;
· the right of erasure
· the right to restrict processing;
· the right to data portability
· the right to object;
· the right not to be subjected to automated decision making, including profiling.
The above rights are not available to data subjects when the legal basis on which WOMEN OF NEWPORT is holding & processing their data are: Subject Consent, Contractual obligation; Legal Obligation; Legitimate Interest
35. Rights of Access, Rectification and Erasure
Data subjects will be clearly informed of their right to access their personal data and to request that any errors or omissions be corrected promptly. Such access shall be given and the correction of errors or omissions shall be made free of charge provided that such requests are reasonable and not trivial or vexatious. There is no prescribed format for making such requests provided that:
a) the request is made in writing, signed and dated by the data subject;
It will be explained to data subjects who make a request to access their data and/or to have errors or omissions corrected, or that their data be erased, that, while their requests will be actioned as soon as is practical there may be delays where the appropriate volunteers or staff to deal with the request do not work on every normal weekday. Where a data subject requests that their data be rectified or erased the Data Controller and Data Processor will ensure that the rectifications or erasure will be applied to all copies of the subject’s personal data including those copies which are in the hands of a Third Party for authorised data processing.
36. Right of Portability
WOMEN OF NEWPORT will only provide copies of personal data to the data subject (or the subject’s legal representative) on written request. WOMEN OF NEWPORT reserves the right either:
a) to decline requests for portable copies of the subject’s personal data when such requests are unreasonable (ie: excessively frequent) or vexatious;
or
b) to make a reasonable charge for providing the copy.
37. Data Retention Policy
Personal data shall not be retained for longer than:
a) in the case of data held by Subject Consent: the period for which the subject consented to WOMEN OF NEWPORT holding their data;
b) in the case of data held by Legitimate Interest of WOMEN OF NEWPORT: the period for which that legitimate interest applies. For example: in the case of data subjects who held a role, such as a volunteer, with WOMEN OF NEWPORT the retention period is that for which WOMEN OF NEWPORT reasonably has a legitimate interest in being able to identify that individual’s role in the event of any retrospective query about it;
c) in the case of data held by Legal Obligation: the period for which WOMEN OF NEWPORT is legally obliged to retain those data.
WOMEN OF NEWPORT shall regularly – not less than every 12 months – review the personal data which it holds and remove any data where retention is no longer justified. Such removal shall be made as soon as is reasonably practical, and in any case no longer than 20 working days (of the relevant Data Processor) after retention of the data was identified as no longer justified.
38. Trustees’ Data
The volume of personal data is very low – fewer than 15 individuals The sensitivity of the data is low-moderate: the most sensitive data being date of birth, previous names and previous addresses;
The risk of data breach is small as the data are rarely used, with the majority of the data being held for a combination of Legal Obligation and Legitimate Interest purposes. Overall impact: LOW
39. Volunteers’ Data
The volume of personal data is low – fewer than 100 individuals The sensitivity of the data is low: the most sensitive data being an e-mail address;
The risk of data breach is small – primarily the accidental disclosure of names & e-mail addresses. Overall impact: LOW
40. Supporters’ & Enquirers’ Data
The volume of personal data is low-moderate. The sensitivity of the data is low: the most sensitive data being an e-mail address;
The risk of data breach is small – primarily the accidental disclosure of names & e-mail addresses. Overall impact: LOW
41. Third Party Access to Data
Under no circumstance will WOMEN OF NEWPORT share with, sell or otherwise make available to Third Parties any personal data except where it is necessary and unavoidable to do so in pursuit of its community objects as authorised by the Data Controller. Whenever possible, data subjects will be informed in advance of the necessity to share their personal data with a Third Party in pursuit of WOMEN OF NEWPORT’s community objects. Before sharing personal data with a Third Party WOMEN OF NEWPORT will take all reasonable steps to verify that the Third Party is, itself, compliant with the provisions of the UK-GDPR and confirmed in a written contract. The contract will specify that:
· WOMEN OF NEWPORT is the owner of the data;
· The Third Party will hold and process all data shared with it exclusively as specified by the instructions of the Data Controller;
· The Third Party will not use the data for its own purposes;
· The Third Party will adopt prevailing industry standard best practice to ensure that the data are held securely and protected from theft, corruption or loss; · The Third Party will be responsible for the consequences of any theft, breach, corruption or loss of WOMEN OF NEWPORT’s data (including any fines or other penalties imposed by the Information Commissioner’s Office) unless such theft, breach, corruption or loss was a direct and unavoidable consequence of the Third Party complying with the data processing instructions of the Data Controller.
· The Third Party will not share the data, or the results of any analysis or other processing of the data with any other party without the explicit written permission of the Data Controller;
· The Third Party will securely delete all data that it holds on behalf of WOMEN OF NEWPORT once the purpose of processing the data has been accomplished.
· WOMEN OF NEWPORT does not, and will not, transfer personal data out of the UK.
42. Data Breach
In the event of any data breach coming to the attention of the Data Controller the trustees will immediately notify the Information Commission’s Office. In the event that full details of the nature and consequences of the data breach are not immediately accessible the trustees will bring that to the attention of the Information Commissioner’s Office and undertake to forward the relevant information as soon as it becomes available.
43. Privacy Policy & Privacy Notices
WOMEN OF NEWPORT will have a Privacy Policy and appropriate Privacy Notices which it will make available to everyone on whom it holds and processes personal data, in accordance with 5.1. In the case of data obtained directly from the data subject, the Privacy Notice will be provided at the time the data are obtained. In the case that the data are not obtained directly from the data subject, the Privacy Notice will be provided within a reasonable period of WOMEN OF NEWPORT having obtained the data or, if the data are used to communicate with the data subject, at the latest, when the first communication takes place; or if disclosure to another recipient is envisaged, at the latest, before the data are disclosed.
