Data Protection Policy
Scope of the Policy
Why this policy exists
This data protection ensures the Association:
- Complies with data protection law and follows good practice
- Protects the rights of members
- Is open about how it stores and processes members' data
- Protects itself from risks of a data breach
General Guidelines for committee members
- The only people able to access data covered by this policy should be those who need to communicate with or provide a service to the Association members.
- The Association will provide induction training to committee members to help them understand their responsibilities when handling data.
- Committee members should keep all data secure, by taking sensible precautions and following the guidelines below.
- Strong passwords must be used, and they should never be shared.
- Data should not be shared outside the U3A unless with prior consent and/or for specific and agreed reasons.
- Membership information should be refreshed periodically to ensure accuracy, via the membership renewal process or when the policy is changed.
- Additional support will be support from the Third Age Trust where uncertainties or incidents regarding data protection arise.
Data Protection Principles
General Data Protection Regulation identifies key data protections principles:
Principle 1 - Personal data should be stored lawfully, fairly and in a transparent manner.
Principle 2 - Personal data must be collected for specific, 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 not considered to be incompatible with the initial purposes.
Principle 3 - The collection of personal data must be adequate, relevant and limited to what is necessary to the purposes for which they are processed.
Principle 4 - Personal data held should be 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.
Principle 5 - Personal data must be 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.
Principle 6 - Personal data must be processed in accordance and 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.
Lawful, fair and transparent data processing
The Association requests personal information from potential members and members for membership applications and for sending communications about their involvement with the Association. The forms used for personal information will contain a privacy statement informing potential members and members as to why the information is being requested and what the information will be used for. The lawful basis for obtaining member information is due to the contractual relationship that the Association has with individual members.
In addition, members will be asked to provide consent in writing for specific processing purposes. Association members will be informed as to who they need to contact should they wish for their data not to be used for specific purposes for which they have provided consent. Where these requests are received they will be acted upon promptly and the member will be informed as to when the action has been taken.
Processed for specific, explicit and legitimate purposes
Members will be informed as to how their information will be used and the Committee of the Association will seek to ensure that member information is not used inappropriately. Appropriate use of information provided by members will include:
- Communicating with members about Association events and activities
- Sending members information about the Association and Third Age Trust events and activities
- Communicating with members about their membership and/or renewal of their membership
- Communicating with members about specific issues that may have arisen during their membership
The Association will ensure that the Association members are made aware of what would be considered appropriate and inappropriate communication. Inappropriate communication would include sending Association members marketing and/or promotional material from external service providers.
The Association will ensure that members information is managed in such a way as to not infringe an individual members rights which include:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
Adequate, relevant and limited data processing
Members of the Association will be only asked to provide information on their contacts that is relevant for membership purposes. This will include:
- Email address
- Telephone Numbers
Where additional information may be required such as health related information this will be obtained with the consent of the member who will be informed as to why this information is required and the purpose that it will be used for.
Where the Association organises an activity that requires next of kin information to be provided, a legitimate interest assessment will have been completed in order to request this information. Members will be made aware that the assessment has been completed.
Photographs are classified as personal data. Where group photographs are being taken members will be asked to step out of shot if they do not wish to be in the photograph. Otherwise consent will be obtained from members for photographs to be taken and members will be informed as to where the photographs will be displayed. Should a member wish at any time to have their photograph removed they should then contact the Association Secretary to advise that they no longer wish their photograph to be displayed.
Accuracy of data and keeping data up to date
The Association has a responsibility to ensure members' information is kept up to date. Members will be informed to let the Association Secretary know if any of their contacts or contacts' personal information changes. In addition, on an annual basis, the membership renewal process will provide an opportunity for members to inform the Association as to any changes in their contacts' personal information.
Accountability and Governance
The Association Committee are responsible for ensuring that the Association remains compliant with data protection requirements and can evidence that it has. Where consent is required for specific purposes then evidence (either electronic or paper) will be obtained and retained securely. The Association Committee will ensure that new members joining the Committee receive an induction into the requirements of GDPR and the implications for their role. Committee Members shall also stay up to date with guidance and practice within the U3A movement and shall seek additional input from The Third Age Trust National Office should any uncertainties arise. The Committee will review data protection and who has access to information on a regular basis as well as reviewing what data is held. When Committee Members relinquish their roles, they will be asked to either pass on data to those who need it and/or delete data.
The Association Committee Members have a responsibility to ensure that data is securely held and processed. This will include:
- Committee Members using strong passwords
- Committee Members not sharing passwords
- Restricting access of sharing member information to those on the Committee who need to communicate with members on a regular basis.
- Using password protection on laptops and PCs that contain personal information.
- Using password protection or secure cloud systems when sharing data between Committee Members.
- Paying for firewall security to be put on to Committee Members laptops or other devices.
Subject Access Request
Association members are entitled to request access to the information that is held by the Association. The request needs to be received in the form of a written request to the Secretary of the Association. On receipt of the request, the request will be formally acknowledged and dealt with expediently and within 7 days unless there are exceptional circumstances as to why the request cannot be granted. The Association will provide a written response detailing all information held on the member. A record shall be kept of the date of the request and the date of the response.
Data Breach Notification
Were a data breach to occur action shall be taken to minimise the harm. This will include ensuring that all the Association Committee Members are aware that the breach has taken place and how the breach occurred. The Committee shall then seek to rectify the cause of the breach as soon as possible to prevent any further breaches. The Chair of the Association shall contact National Office within 24 hours of the breach occuring to notify of the breach. A discussion will take place between the Chair and the National Office as to the seriousness of the breach, action to be taken and, where necessary, the information Commissioner's Office would be notified. The Committee shall also contact the relevant Association members to inform them of the data breach and the actions taken to resolve the breach.
Where an Association member feels that there has been a breach by the Association, a committee member will ask the member to provide an outline of the breach. If the initial contact is by telephone, the committee member will ask the Association member to follow this up with an email or letter detailing their concern. The alleged breach will then be investigated by members of the committee who are not in any way implicated in the breach. Where the committee needs support or if the breach is serious they should notify National Office. The Association member should also be informed that they can report their concerns to National Office if they don't feel satisfied with the response from the Association. Breach manners will be subject to a full investigation, records will be kept and all those involved notified of the outcome.
Policy agreed: 26th September 2018
Policy review date: September 2019