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Data Protection Policy

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Introduction

The reason for this policy is to define WAY Widowed and Young’s approach to the processing of personal data and the standards it will adopt.   This document defines the minimum standards and best practice requirements adopted by WAY Widowed and Young to make certain that it meets the requirements of the relevant legislation, and to ensure we meet the expectations of those whose data we process. 

In undertaking its charitable purpose WAY Widowed and Young needs to process personal data which relates to members, staff, volunteers, trustees, supporters, contractors and organisations/individuals it works with to campaign and raise awareness.  This policy sets out the standards which must be adhered to, when personal data is being processed by, or on behalf of, WAY Widowed and Young. 

Data Protection Principles

WAY Widowed and Young is committed to processing data in accordance with its responsibilities under the GDPR. 

Article 5 of the GDPR requires that personal data shall be:

  1. Processed lawfully, fairly and in a transparent manner in relation to individuals;
  2. 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;
  3. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. 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;
  5. Kept in a form which 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 GDPR in order to safeguard the rights and freedoms of individuals; and
  6. 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.”

General Provisions

  1. This policy applies to all personal data processed by WAY Widowed and Young.
  2. The policy applies to all areas within WAY Widowed and Young’s operation, this being the United Kingdom, comprising of; England, Wales, Scotland and Northern Ireland, and to the personal data of any individual regardless of where in the world they are located. 
  3. The Responsible Person shall take responsibility for WAY Widowed and Young’s ongoing compliance with this policy. 
  4. Where appropriate, WAY Widowed and Young will develop further policies, procedures, and guidelines which if followed correctly will facilitate the achievement of compliance with the requirements of the relevant legislation by individuals processing personal data in the course of their WAY Widowed and Young duties.
  5. This policy shall be reviewed at least annually. 
  6. WAY Widowed and Young is registered with the Information Commissioner’s Office as an organisation that processes personal data. 

Lawful, fair and transparent processing 

  1. To ensure its processing of data is lawful, fair and transparent, WAY Widowed and Young shall maintain a Register of Systems. 
  2. The Register of Systems shall be reviewed at least annually. 
  3. Individuals have the right to access their personal data and any such requests made to WAY Widowed and Young shall be dealt with in a timely manner.  (See Subject Access requests below.)

Lawful purposes

  1. All data processed by WAY Widowed and Young, must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information). 
  2. WAY Widowed and Young shall note the appropriate lawful basis in the Register of Systems.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data. 
  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in WAY Widowed and Young’s systems. 

Data Minimisation

  1. WAY Widowed and Young, shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

 Third Parties

  1. Personal data shall only be transferred outside of WAY to a third party where there is a legitimate business reason for doing so.   Third Parties must be subject to; due diligence checks and an agreement must be in place which details the purposes for which the data is transferred and restricts the use of the data to those purposes.   
  2. To ensure that personal data is kept for no longer than necessary, WAY Widowed and Young shall put in place retention guidelines for each area in which data is processed.  The guidelines shall consider what data should/must be retained, and for how long.  See Appendix 1.  
  3. WAY Widowed and Young may be under a legal obligation to retain personal data for a specific period, and compliance with our legal obligation may limit the right of an individual to have their personal data erased.  Where rights are exercised under data protection law and this conflicts with any requirement or need for the charityto retain personal data, individuals will be advised that this is the case and will be provided with a timeframe within which WAY Widowed and Youngexpect to comply with the right. 

Accuracy

  1. WAY Widowed and Young shall take reasonable steps to ensure personal data is accurate.
  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date. 
  3. Members of WAY Widowed and Young can update their own details within their profile at any time by logging into the member’s area at www.widowedandyoung.org.uk.  
  4. Individuals have the right to request their personal data is accurate, requests made to WAY Widowed and Young shall be dealt with in a timely manner. 

Security

  1. Everyone who processes personal data on behalf of WAY shall ensure they take all appropriate and reasonable precautions to prevent a personal data breach occurring.
  2. WAY Widowed and Young shall ensure that personal data is stored securely using modern software that is kept up-to-date. 
  3. Access to personal data shall be limited to personnel who need access and appropriate security is in place to avoid unauthorised sharing of information. 
  4. When personal data is deleted this should be done safely such that the data is irrecoverable. 
  5. Appropriate back-up and disaster recovery solutions are in place. 

Retention and Removal

  1. To ensure that personal data is kept for no longer than necessary, WAY Widowed and Young shall put in place retention guidelines for each area in which data is processed.  The guidelines shall consider what data should/must be retained, and for how long.  for a copy of our retention guidelines please contact us. 
  2. WAY Widowed and Young may be under a legal obligation to retain personal data for a specific period, and compliance with our legal obligation may limit the right of an individual to have their personal data erased.  Where rights are exercised under data protection law and this conflicts with any requirement or need for the charityto retain personal data, individuals will be advised that this is the case and will be provided with a timeframe within which WAY Widowed and Youngexpect to comply with the right. 

Subject Access Requests (SAR)

If you wish to make a request for ‘personal data’under the Data Protection Act (DPA) 2018 you must do so in writing to The Chief Executive, WAY Widowed and Young, Suite 14, College Business Park, Uttoxeter New Road, Derby, DE22 3WZ

  1. Your application (SAR) must be accompanied by copies of at least two official documents, which show your name, date of birth and current address, e.g. driving licence, birth/adoption certificate, passport, recent utility bill. 
  2. Please supply as much detail as possible in order that we provide the most relevant information in relation to your request.  
  3. WAY Widowed and Young will respond to the request made within one month of receipt.    The charity will only extend the period of compliance by a maximum of a further two months where requests are complex or numerous.  If this is the case, we will inform the individual within one month of the receipt of the request and explain why the extension is necessary.
  4. Information is provided free of charge. However, where a request is ‘manifestly unfounded or excessive’ WAY Widowed and Young, may charge a reasonable administrative cost fee.
  5. WAY Widowed and Youngcan withhold personal data if disclosing it would ‘adversely affect the rights and freedoms of others'

 Breach

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, WAY Widowed and Young 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).

Other relevant policies

The following policies of WAY Widowed and Young may also be relevant to Data protection matters:

  1. Privacy Policy
  2. Confidentiality Policy 
  3. Safeguarding and Welfare Policy
  4. Complaints Policy

 Changes to this Policy

WAY Widowed and Young, reserve the right to change this policy at any time.  In which case the amended policy will be updated on our website and will apply from the date we post them.   

 The format and content of our website changes constantly.  You should refresh your browser each time you visit our sites to ensure that you access the most up to date version.

Our Contact Details

We can be contacted in the following ways:

WAY Widowed and Young, Suite 14, College Business Park, Uttoxeter New Road, Derby, DE22 3WZ or enquiries@widowedandyoung.org.uk

Definitions

Charity

WAY Widowed and Young, a registered charity.

GDPR

General Data Protection Regulation.

Personal Data

Means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; 

Processing

Means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. 

 

Responsible Person

Chief Executive

Register of Systems

A register of all systems or contexts in which personal data is processed by WAY Widowed and Young.


Agreed by WAY Board of Trustees, Meeting Date 1st June 2019