Data Protection Policy
Context & Overview
- Policy Prepared by: Karen Smith (Administration Manager)
- Approved by Board on: 27th June, 2018
- Policy Became Operational On: 27th June, 2018
- New review Date: 27th June, 2019
The Roddick Foundation needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees 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 law.
Why This Policy Exists
This data protection policy ensures The Roddick Foundation:
- Complies with data protection law and follows good practice
- Protects the rights of staff, customers and others.
- 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 describes how organisations – including The Roddick Foundation – 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:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
- Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection.
People, Risks & Responsibilities
This policy applies to:
- The office of The Roddick Foundation
- All staff and volunteers of The Roddick Foundation
- All contractors, suppliers and other people working on behalf of The Roddick Foundation.
It application to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:
- Name of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- …plus any other information relating to individuals.
Data Protection Risks
This policy helps to protect The Roddick Foundation from some very real data security risks including:
- Breaches of confidentiality – for example, information being given out inappropriately.
- Failing to offer choice – for example, all individuals should be free to choose how the company uses data relating to them.
- Reputational damage – for example, the company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with The Roddick Foundation has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team 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 Board of Trustees is ultimately response for ensuring that The Roddick Foundation meets its legal obligations.
- The Grants Manager is responsible for:
- Keeping the board 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 The Roddick Foundation holds about them (also called ‘subject access requests’).
- Checking and approving and contracts or agreement with third parties that may handle the company’s sensitive data.
- The Administration Manager is responsible for:
- 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 e.g. cloud computing services.
- The Grants Manager is responsible for:
- Approving 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 should not be shared informally. When access to confidential information is required, employees can request if from their line managers.
- The Roddick Foundation can, where necessary, provide training to all employees 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 suitably disposed of.
- Employees should request help from their line manager if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Grants Manager or Administration 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 employees.
- If data is stored on removable media, these should be kept securely locked away when not being used.
- Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
- Servers containing personal data should be sited in a secure location, away from general office space.
- Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
- All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to The Roddick Foundation unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
- When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
- Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
- Data must be encrypted before being transferred electronically.
- Personal data should never be transferred outside of the European Economic Area.
- Employees should not save copies of personal data to their own computers.
The law requires The Roddick Foundation to take reasonable steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater effort The Roddick Foundation should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible:
- Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
- Staff should take every opportunity to ensure data is updated.
- Data should be updated as inaccuracies are discovered.
Subject Access Requests
All individuals who are the subject of personal data held by The Roddick Foundation are entitled to:
- Ask what information the company holds about them and why.
- Ask how to gain access to it.
- Be informed how data is kept up to date.
- Be informed how the company is meeting its data protection obligations.
If an individual contacts the company requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the Administration Manager at email@example.com. Individuals may be charged an administrative cost per subject access request.
The Administration Manager 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, The Roddick Foundation will disclose requested data. However, the request must be proved to be legitimate by the relevant Manager, and this may involve seeking assistance from the Board of Trustees and from the company’s legal advisers where necessary.
The Roddick Foundation aims to 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
If you are not happy with how we have handled your data, then please contact the Administration Manager at firstname.lastname@example.org.