Data Protection Policy
Last updated: 10th May 2019
||Isfield and Little Horsted Bonfire Society.
||General Data Protection Regulation.
||Information Commissioner’s Office
| Responsible Person
||the Membership Secretary of the Society|
|Register||a register of members of the Society|
1. Data protection principles
The Society is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR 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 GDPR 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.
2. General provisions
This policy applies to all personal data processed by the Society.
The Responsible Person shall take responsibility for the Society’s ongoing compliance with this policy.
This policy shall be reviewed at least annually.
3. Personal Information
We use appropriate procedures and technical security measures including an encrypted database to safeguard your personal information.
The information held is taken directly from the membership form and contains:
c. Date of Birth
d. Telephone and mobile numbers
e. Email address
f. Emergency contact name and telephone numbers
g. Medical condition that the society needs to know
h. Guardian name (if a Junior member)
When attending other bonfire society events a list containing items a, d, e and g will be carried by nominated Health and Safety Officer for the evening.
4. Lawful Purposes
All data processed by the Society is done on the basis of consent
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 Society’s register of members.
5. Data minimisation
The Society shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
The Society 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.
7. Archiving / removal
To ensure that personal data is kept for no longer than necessary, the Society 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.
The Society shall ensure that personal data is stored securely
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.
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 Society shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO