Lions Club of Tavistock
Data Protection

Lions Club of Tavistock - Data Protection Policy

Introduction

Lions Club of Tavistock needs to gather and use certain information about individuals, their names and addresses and e-mail in connection with our activities. This policy describes how e personal details are handled and stored to meet data protection standards and obligations and to comply with the law and regulatory requirements.

Why this policy exists

This data protection policy ensures that Lions Club of Tavistock :

·         Complies with data protection law and follows good practice.

·         Protects the rights of individuals

·         Is open and transparent 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

The data protection act 1998 describes how organisations – including Lions Club of Tavistock - 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

GDPR – The General Data Protection Regulation 2018

The General Data Protection Regulation (GDPR) is European Union legislation that will begin to be enforced on May 25, 2018.

Its aim is to strengthen the rights of data subjects within the European Union (EU) and European Economic Area (EEA) with regard to how their personal data is used and how it’s protected. (‘Personal data’ means any information that relates to an identified or identifiable natural person.  An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, ID number, location data, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person). Lions Club of Tavistock do not hold any data relating to items categorised as “Special Categories of Personal Data” as defined within GDPR (Race, Religion, Political Opinions, Trade Union Membership, Sexual Orientation, Health information, Biometric Data or Genetic Data).

The GDPR applies to any organization inside or outside the EU who is marketing goods or services to, and/or tracking the behaviours of, data subjects within the EU and EEA.

The GDPR is structured around six key principles (detailed in Article 5 of the legislation):

1. Transparency on how data will be used and what it will be used for.

2. Ensuring that the data collected is used only for the purposes explicitly specified at the time of collection.

3. Limiting the data collection to what is necessary to serve the purpose for which it is collected.

4. Ensuring the data is accurate.

5. Storing the data for only as long as necessary within its intended purpose.

6. Prevention against unauthorized use or accidental loss of the data through the deployment of appropriate security measures.

In addition, the GDPR includes a new accountability requirement to be able to demonstrate how compliance with the principles is being managed and tracked. This requires the maintenance of records of how and why personal data was collected, how and when consent was given, as well as the documentation of the processes put in place to protect it.

Policy scope

This policy applies to all data that the organisation holds relating to identifiable individuals, this can include:

• Names of individuals

• Postal addresses

• Email addresses

• Telephone numbers

• Plus any other information relating to an identifiable natural person

Data Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Data Subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subjects wishes where he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Your Personal Data

What data we need

Unless otherwise agreed with you, we will only collect basic personal data about you, which does not include any special categories of personal information about you (often known as “sensitive personal data”).  The basic personal data we collect about you does include: name, telephone number(s), email and occasionally business address.

Why we need it

We need to know basic personal data in order to administer our activities

We will not collect any personal data from you that we do not need in order to provide the above mentioned activities.

What we do with it

All personal data we hold about you will be processed by our team and no additional third parties will have access to your personal data unless there is a legal obligation for us to provide it.  Please be aware that your personal data will be stored on a cloud-based system whose servers are located within the European Union.

We take all reasonable steps to ensure that your personal data is processed securely and more information on this can be found in our Data Protection Policy.

How long we keep it

We will generally keep your personal data for a minimum of two years, after which time it will be destroyed if it is no longer required for the lawful purpose(s) for which it was obtained. 

What are your rights

If at any point you believe the information we process on you is incorrect, you can request to see this information and have it corrected or deleted. If you wish to raise a complaint on how we have handled your personal data, you can email us to have the matter investigated at itsupport@tavistocklions.org.uk

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office https://ico.org.uk/

Lions Club of Tavistock  will also collect and store details in relation to the data subjects consent to contact.  These details will include:

• Affirmative consent to processing (Yes/No)

• Date upon which consent was given

• Date upon which consent was last updated

• Consent Notes (how consent was obtained and for what purposes)       

Responsibilities

Data Storage

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

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

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

• Data will be protected by strong passwords that are changed regularly.

• Some personal data will be stored on secured cloud computing services.

Data Accuracy

The law requires Lions Club of Tavistock to take reasonable steps to ensure data is kept accurate and up to date. 

• Data will be held in as few places as necessary. 

Subject Access Requests

All individuals who are the subject of personal data held by Lions Club of Tavistock are entitled to:

• Ask what information the club holds about them and why

• Ask how to gain access to it

• Be informed how to keep it up to date

• Be informed how the organisation is meeting its data protection obligations

If an individual contacts the club requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the administrator@tavistocklions.org.uk The Administrator can supply a standard request form, although individuals do not have to use this.

The Club will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Lions Club of Tavistock will disclose requested data.  However, the administrator will ensure the request is legitimate.

Providing Information

Lions Club of Tavistock will ensure that individuals are aware that their data is being processed, and that they understand:

• How the data is being used

• How to exercise their rights

To these ends, the club has a privacy statement, setting out how data relating to individuals is used by the club.  This document is available on request and is also on the company’s website.

Rights of the data subject

Right of confirmation

Each data subject shall have the right to obtain from the controller the confirmation as to whether or not personal data concerning them are being processed.  If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact our administrator.

Right of access

Each data subject shall have the right to obtain from the controller free information about his or her personal data stored at any time and a copy of this information.  Furthermore, the European directives and regulations grant the data subject access to the following information:

• The purposes of the processing

• The categories of personal data concerned

• The recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organisations

• Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period.

• The existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing.

• The existence of the right to lodge a complaint with a supervisory authority

• Where the personal data are not collected from the data subject, any available information as to their source

• The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significant and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have the right to obtain information as to whether personal data are transferred to a third country or to an international organisation.  Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may at any time contact our administrator

Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her.  Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact our administrator.

Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.

• The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.

• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.

• The data subject had objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Lions Club of Tavistock, he or she may at any time contact our administrator.  The Administrator will arrange the restriction of the processing.

Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format.  He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) or Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible, and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact the Administrator.

Right to Object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to the processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GSPR.  This also applies to profiling based on these provisions.

Lions Club of Tavistock shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

In order to exercise the right to object, the data subject may directly contact the administrator.  In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC.to use his or her right to object by automated means using technical specifications.

Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact our administrator.