Data protection policy

Posted on by

Worcester Action for Youth

Last updated

22nd May 2018

Definitions

Charity

Worcester Action for Youth, a registered charity No. 1169888

GDPR

General Data Protection Regulation.

Responsible Person

Manager.

Register of Systems

Register of all systems or contexts in which personal data is processed by the Charity, as set out in Appendix A.

1. Data protection principles

The Charity 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.a??

2. General provisions

  1. This policy applies to all personal data processed by the Charity.

    A?

  2. The Responsible Person shall take responsibility for the Charitya??s ongoing compliance with this policy.

    A?

  3. This policy shall be reviewed at least annually.

3. Lawful, fair and transparent processing

  1. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems, as set out in Appendix A.
  2. The Register of Systems shall be reviewed at least annually.

    A?

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

4. Lawful purposes

  1. All data processed by the charity 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). In general, the Charity will only hold personal data to comply with a legal obligation but may rely on Consent or Legitimate Interest for certain types of data.

  2. The Charity shall note the appropriate lawful basis in the Register of Systems (Appendix A)

  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 shall be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Charitya??s systems.

5. Data minimisation

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

6. Accuracy

  1. The Charity 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.

7. Archiving / removal

  1. To ensure that personal data is kept for no longer than necessary, the Charity shall annually review the personal data that it holds, considering what data should/must be retained, for how long, and why.

  2. Data retention periods are set out in Appendix A

8. Security

  1. The Charity shall ensure that personal data is stored securely using appropriate software that is kept-up-to-date and password protected. Where the data is held in paper form, it will be stored in a locked cabinet.

  2. Access to personal data shall be limited to personnel who need access and apropriate security shall be in place to avoid unauthorised sharing of information.

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

  4. Appropriate back-up solutions shall be in place.

9. 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 Charity shall promptly assess the risk to peoplea??s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).

END OF POLICY
Appendix A

DATA AUDIT

Review of all databases, email lists, spreadsheets, paper documents and other lists of personal data.

Description

Why is the data held and what is it used for

Basis for processing data (e.g.

consent, legal obligation etc)

Who holds the data and who can access it?

What security controls are in place?

How long is data kept for?

Is this covered by our privacy notice?

ACTION REQUIRED

Example: Gift Aid Declarations

For claiming Gift Aid

Legal obligation

Held by Gift Aid Officer. Also accessed by treasurer

Paper declarations kept in a filing cabinet.

Spreadsheet on PC

Six complete calendar years after last gift claimed on the declaration

Yes

Password protect the spreadsheet

Payroll software

To pay wages to staff and Activity Workers

Legal obligation

Payroll software and database held on Treasurera??s laptop. Backup of data held on Treasurera??s PC

Boot-up and screen save password on laptop and also on PC

Minimum 3 years after tax year end. Keep salary/pay, redundancy records, SSP/SMP for six years alongside other

personnel records

Yes

None

Payroll spreadsheet

Used to double- check the payroll amounts and

combine with expenses not

Legitimate interest

Spreadsheet held on

Treasurera??s PC

Boot-up and screen save password on PC and

password on spreadsheet

Minimum 3 years after tax year end. Keep for six years

alongside other personnel

Yes

Password added to spreadsheet

A?

A?

on the payroll system. Used to notify employees of

monthly payment

A?

A?

A?

records

A?

A?

Personnel files

To maintain appropriate records of employees

Legal obligation and contract

Files stored in locked cabinet. Access only by WAY Manager

and Chair of Trustees

Stored in locked cabinet

Current Employees a?? indefinitely. Former employees a??

six years

Yes

None

Recruitments records (unsuccessful candidates)

In order to recruit employees

Legal obligation

Files stored in locked cabinet. Emails stored in email system. Access only by WAY Manager and Chair of

Trustees

Stored in locked cabinet

A?

Password protection of email system

One year

Yes

None

DBS checks

To meet legal requirement

Legal obligation

Stored on personnel files in locked cabinet. Access only by WAY Manager and Chair of

Trustees

Stored in locked cabinet

Six months

Yes

None

Pension auto- enrolment and opt-outs

To meet legal requirement to offer pensions

Legal obligation

Stored on personnel files in locked cabinet. Access only by WAY

Manager and Chair of

Stored in locked cabinet

Six years, except for opt- outs which are kept for four years

Yes

None

A?

A?

A?

A?

Trustees

A?

A?

A?

A?

Email contact

To enable

Legitimate

Stored in email

Password

Current

Yes

None

details

contact with

interest

system. Access

protected of

contacts a??

A?

A?

A?

youth

A?

by WAY

email system

indefinitely,

A?

A?

A?

organisations

A?

Manager,

A?

Former

A?

A?

A?

using WAYa??s

A?

admin staff and

A?

contacts a?? six

A?

A?

A?

services and to

A?

Chair of

A?

years

A?

A?

A?

contact Activity

A?

Trustees

A?

A?

A?

A?

A?

Workers

A?

A?

A?

A?

A?

A?

Trustee

To meet legal

Legal

Files stored in

Stored in

Current

Yes

None

details. Name,

requirement

obligation

locked cabinet.

locked cabinet

Trustees a??

A?

A?

address and

A?

A?

Access only by

A?

indefinitely.

A?

A?

phone

A?

A?

WAY Manager

A?

Former

A?

A?

number

A?

A?

and Chair of

A?

Trustees a?? six

A?

A?

A?

A?

A?

Trustees

A?

years

A?

A?

Donor details

To satisfy

Legal

Donor details

Stored on

Six years

Yes

None

(personal

requirement to

obligation

recorded in

Treasurera??s PC

A?

A?

A?

donors only).

keep adequate

A?

Quickbooks

with boot-up

A?

A?

A?

Name of

accounting

A?

accounting

and screen save

A?

A?

A?

donor

records

A?

software

password.

A?

A?

A?

A?

A?

A?

accessible by

Accessed

A?

A?

A?

A?

A?

A?

Treasurer

through

A?

A?

A?

A?

A?

A?

A?

Quickbooks on-

A?

A?

A?

A?

A?

A?

A?

line system

A?

A?

A?

A?

A?

A?

A?

with password

A?

A?

A?

Working time

Legal

Legal

Timesheets

Stored in

Six years

Yes

None

records for

requirement

obligation

held with

locked cabinet

A?

A?

A?

employees

and contract

A?

payment

A?

A?

A?

A?

A?

A?

A?

records in

A?

A?

A?

A?

A?

A?

A?

payment

A?

A?

A?

A?

A?

A?

A?

vouchers file

A?

A?

A?

A?

A?

A?

A?

accessible by

A?

A?

A?

A?

A?

A?

A?

Treasurer and

A?

A?

A?

A?

A?

A?

A?

WAY Manager

A?

A?

A?

A?

Attendees at

To monitor that

Legitimate

Attendance

Stored in a

Six years

Yes

None

A?

activity sessions. First name of youth, first three digits of postcode and

age range recorded

the Charitya??s objectives are being met and to fulfil grant requirements

interest. Individuals cannot be identified from the data collected

logs are held by and accessible to the WAY Manager

locked cabinet

A?

A?

A?

Ambassadors Project. First name of youth and age range recorded

To monitor that the Charitya??s objectives are being met and to fulfil grant requirements

Legitimate interest.

Individuals cannot be identified from the data collected

Interview responses and analysis are held by Activity Evaluator and in a spreadsheet held on Activity Evaluator computer and WAY Managera??s

computer

Stored in a locked cabinet.

A?

Boot-up and screen save password

A?

Spreadsheet password

Six years

Yes

Password added to spreadsheet

Gift Aid declarations (none currently)

Legal requirement

Legal obligation

Held and accessible by the WAY Manager

Store in locked cabinet

Six years

Yes

None