Adopted 05/11/2019
1. Introduction
This document sets out how Tay Valley Timebank will;
• comply with the legal obligations in respect of the data it holds about individuals;
• ensure the trustees, employees, volunteers and members of Tay Valley Timebank understand their responsibilities; and follow good practice.
2. Data Protection Principles
Tay Valley Timebank is committed to processing data in accordance with its responsibilities under the General Data Protection Regulation (“GDPR”).
Article 5 of the GDPR requires that personal data shall be:
a) processed lawfully, fairly and in a transparent manner in relation to individuals;
b) 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;
c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d) 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;
e) 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
f) 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.
3. General Provisions
This policy applies to all personal data processed by Tay Valley Timebank.
The Secretary shall take responsibility for Tay Valley Timebank’s ongoing compliance with this policy and ensure that it is reviewed at least annually.
4. Lawful, fair and transparent processing
To ensure its processing of data is lawful, fair and transparent, Tay Valley Timebank shall maintain a Register of Records; this will detail the applications and systems that hold data and will be reviewed on an annual basis.
Individuals have the right to access their personal data and any such requests made to Tay Valley Timebank shall be dealt with in a timely manner. Data Protection Policy – Adopted 05/11/2019 SCIO 049606
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5. Lawful purposes
All data processed by Tay Valley Timebank 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).
Tay Valley Timebank shall note the appropriate lawful basis in the Register of Records.
Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
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 Tay Valley Timebank’s records.
6. Data minimisation
Tay Valley Timebank shall ensure that personal data are adequate, relevant and limited
to what is necessary in relation to the purposes for which they are processed.
7. Accuracy
Tay Valley Timebank 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.
8. Archiving/removal
To ensure that personal data is kept for no longer than necessary, Tay Valley Timebank shall maintain a Register of Records which shall be reviewed annually.
The Register of Records shall detail what data should/must be retained, for how long, and why.
9. Security
Tay Valley Timebank shall ensure that personal data is stored securely using where possible encryption or accessible by password only.
Access to personal data shall be limited to personnel who need access and appropriate security will be in place to avoid unauthorised sharing of information.
When personal data is deleted this should be done safely such that the details are irrecoverable.
Appropriate back-up and disaster recovery solutions shall be in place.
10. 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, Tay Valley Timebank shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
