RC Morden data protection policy

This document has been produced by IT Donut, www.itdonut.co.uk, a website offering technology advice for small businesses. It has been adapted for use by the Rotary Club of MORDEN (also known as RC MORDEN) as a data protection policy.

RC MORDEN Data protection policy

Context and overview

Key details

• Policy prepared by: John de Ronde

• Approved by board RC MORDEN management on: 25 May, 2018

• Policy became operational on: 25 may, 2018

• Next review date: 01 May, 2019

Introduction

RC MORDEN needs to gather and use certain information about individuals.

These include donors, volunteers, contacts, personnel and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures RC MORDEN:

• Complies with data protection law and follows good practice

• Protects the rights of staff, donors, volunteers and partners

• Is open about how it stores and processes individuals’ data

• Protects itself from the risks of a data breach

Data protection law

The Data Protection Act 1998 and the new GDPR regulations describes how organisations such as RC MORDEN must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

1. Be processed fairly and lawfully

2. Be obtained only for specific, lawful purposes

3. Be adequate, relevant and not excessive

4. Be accurate and kept up to date

5. Not be held for any longer than necessary

6. Processed in accordance with the rights of data subjects

7. Be protected in appropriate ways

8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

People, risks and responsibilities

Policy scope

This policy applies to:

• The head office of RC MORDEN

• All staff and volunteers of RC MORDEN

• All contractors, suppliers and other people working on behalf of RC MORDEN

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998 or the new GDPR regulations. This can include:

• Names of individuals

• Postal addresses

• Email addresses

• Telephone numbers

• …plus any other information relating to individuals

Data protection risks

This policy helps to protect RC MORDEN from some very real data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately.

• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.

• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with RC MORDEN has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team member that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

• The RC MORDEN Council are ultimately responsible for ensuring that RC MORDEN meets its legal obligations.

• Data protection issues and IT management shall fall within the remit of the IT Representative, John de Ronde, who is responsible for:

• Data

• Keeping trustees updated about data protection responsibilities, risks and issues.

• Reviewing all data protection procedures and related policies, in line with an agreed schedule.

• Arranging data protection training and advice for the people covered by this policy.

• Handling data protection questions from staff and anyone else covered by this policy.

• Dealing with requests from individuals to see the data RC MORDEN holds about them (also called ‘subject access requests’).

• Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

• IT

• Ensuring all systems, services and equipment used for storing data meet acceptable security standards.

• Performing regular checks and scans to ensure security hardware and software is functioning properly.

• Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.

• Marketing

• Approving any data protection statements attached to communications such as emails and letters.

• Addressing any data protection queries from journalists or media outlets like newspapers.

• Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General staff guidelines

• The only people able to access data covered by this policy should be those who need it for their work.

• Data shall not be shared informally. When access to confidential information is required, personnel can request it from the operations manager.

• RC MORDEN will provide all relevant information to all personnel to help them understand their responsibilities when handling data.

• Employees should keep all data secure, by taking sensible precautions and following the guidelines below.

• In particular, strong passwords must be used and they should never be shared.

• Personal data should not be disclosed to unauthorised people, either within the company or externally.

• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the operations manager.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

• When not required, the paper or files should be kept in a locked drawer or filing cabinet.

• Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.

• Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

• Data should be protected by strong passwords that are changed regularly and never shared between personnel.

• If data is stored on removable media (such as USB Flash drive), these should be kept locked away securely when not being used.

• Data should only be stored on designated drives and servers, and should only be uploaded to a password-protected cloud computing service