Data Protection Policy Rottingdean Village Public Hall

Last updated 16th May 2021.

Definitions Organisation: Rottingdean Village Public Hall

 

DPA: means the Data Protection Act 2018 which implements the EU’s General Data Protection Regulation

 

Responsible Person: means Lesley Arnold (lesley797@gmail.com), Secretary, Rottingdean Village Public Hall

Register of Systems: means a register of all systems or contexts in which personal data is processed by the Organisation

 

Data Protection Principles

 

The Organisation is committed to processing data in accordance with its responsibilities under the DPA.

DPA requires that personal data shall be:

  • Processed lawfully, fairly and in a transparent manner in relation to individuals;

  • 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;

  • Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

  • 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;

  • 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 DPA in order to safeguard the rights and freedoms of individuals; and

  • 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

  • This policy applies to all personal data processed by the Organisation.

  • The Responsible Person shall take responsibility for the Organisation’s ongoing compliance with this policy.

  • This policy shall be reviewed at least annually.

  • The Organisation shall register with the Information Commissioner’s Office as an organisation that processes personal data.

 

Lawful, Fair and Transparent Processing

  • To ensure its processing of data is lawful, fair and transparent, the Organisation shall maintain a Register of Systems.

  • The Register of Systems shall be reviewed at least annually.

  • Individuals have the right to access their personal data and any such requests made to the Organisation shall be dealt with in a timely manner.

     

Lawful Purposes

  • All data processed by the Organisation 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).

  • The Organisation shall note the appropriate lawful basis in the Register of Systems.

  • Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.

  • 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 the Organisation’s systems.

 

Data Minimisation

  • The Organisation shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

 

Accuracy

  • The Organisation shall take reasonable steps to ensure personal data is accurate.

  • 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.

 

Archiving / Removal

  • To ensure that personal data is kept for no longer than necessary, the Organisation shall put in place an archiving policy for each area in which personal data is processed and review this process annually.

  • The archiving policy shall consider what data should/must be retained, for how long, and why.

 

Security

  • The Organisation shall ensure that personal data is stored securely using modern software that is kept-up-to-date.

  • 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.

  • When personal data is deleted this should be done safely such that the data is irrecoverable.

  • Appropriate back-up and disaster recovery solutions shall be in place.

 

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, the Organisation 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).

Privacy Policy

Privacy Policy This Privacy Policy applies to information we Rottingdean Village Public Hall collect about individuals who interact with our organisation. It explains what personal information we collect and how we use it.

 

If you have any comments or questions about this notice, feel free to contact us at lesley797@gmail.com.

 

Personal Data That We Process

 

The following explains the types of data we collect and the legal basis, under current data protection legislation, on which this data is processed.

  • Enquiring about our organisation and its work, Data (key elements) are Name, email, message. Legitimate interests means it is necessary for us to read and store your message so that we can respond in the way that you would expect.

  • Subscribing to email updates about our work, Data (Key elements) are Name, email. Legitimate interests means Consent - you have given your active consent.

  • Website Functionality, Data (key elements) are Website activity collected through cookies. Legitimate interests means it is necessary for us to store a small amount of information, usually through cookies, to deliver functionality that you would expect, such as remembering the contents of your order before you have fully completed the process.

 

How We Use Your Data

 

We will only use your data in a manner that is appropriate considering the basis on which that data was collected, as set out in the table at the top of this policy. For example, we may use your personal information to:

  • Reply to enquiries you send to us;

  • Where you have specifically agreed to this, send you marketing communications by email relating to our work which we think may be of interest to you.

 

When We Share Your Data

 

We will only pass your data to third parties in the following circumstances:

 

  • You have provided your explicit consent for us to pass data to a named third party;

  • We are using a third party purely for the purposes of processing data on our behalf and we have in place a data processing agreement with that third party that fulfils our legal obligations in relation to the use of third party data processors; or

  • We are required by law to share your data.

  • Our overriding policy is to never pass on your data to a third party. In addition, we will only pass data to third parties outside of the EU where appropriate safeguards are in place as defined by Article 46 of the General Data Protection Regulation.

 

How Long We Keep Your Data

 

We take the principles of data minimisation and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required. Where data is collected on the basis of consent, we will seek renewal of consent at least every three years.

 

Rights You Have Over Your Data

 

You have a range of rights over your data, which include the following:

  • Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this (for example by putting ‘unsubscribe’ links at the bottom of all our marketing emails).

  • You have the right to ask for rectification and/or deletion of your information.

  • You have the right of access to your information.

  • You have the right to lodge a complaint with the Information Commissioner if you feel your rights have been infringed.

 

A full summary of your legal rights over your data can be found on the Information Commissioner’s website here: ico.org.uk

 

If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us. Please note that relying on some of these rights, such as the right to deleting your data, will make it impossible for us to continue to deliver some services to you. However, where possible we will always try to allow the maximum access to your rights while continuing to deliver as many services to you as possible.

 

Cookies & Usage Tracking

 

A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, eg remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website. Where cookies are used to collect personal data, we list these purposes in the first section above, along with other personal data that we collect. However, we also use some cookies that do not collect personal information but that do help us collect anonymous information about how people use our website. We use Google Analytics for this purpose.

 

Google Analytics generates statistical and other information about website usage by means of cookies, which are stored on users' computers. The information collected by Google Analytics about usage of our website is not personally identifiable. The data is collected anonymously, stored by Google and used by us to create reports about website usage. Google's privacy policy is available at google.com/privacypolicy.

 

Modifications

 

We may modify this Privacy Policy from time to time and will publish the most current version on our website. If a modification meaningfully reduces your rights, we'll notify people whose personal data we hold and is affected.