Privacy policy

Document description

This policy sets out the way in which Re-engage conforms to data protection legislation and protects all personal data held within its systems.

Implementation and quality assurance

It is the responsibility of the strategic leadership team to ensure that this policy is implemented consistently across the charity, and to that end regular training on data protection and security generally, and this policy in particular, is provided to all members of staff working for the charity who handle data, and all volunteers including co-ordinators.

Implementation is immediate and this policy shall stay in force until any amendments are formally agreed by the board of trustees.

This policy and procedure will be formally reviewed by the board of trustees every year in conjunction with senior managers. Where review is necessary due to legislative change this will happen immediately.

Purpose and principles

The purpose of this policy is to set out the principles of data protection that we follow. The Data Protection Act 2018 and the General Data Protection Regulations (“the UK GDPR”)  provides for the regulation of the processing of information relating to individuals and aims to strike a balance between the privacy rights of individuals and the ability of organisations to use personal information to conduct their business. Re-engage recognises that the lawful and correct treatment of personal information is fundamental to the achievement of our objectives. The largest categories of people we hold information about are volunteers and older people in our services. We also hold information on donors, supporters, staff, and our board. All personal information must be collected, stored, used, and disposed, of properly in accordance with the principles of the DPA and other relevant privacy law, including the Human Rights Act 1998.

Definitions

Data protection principles

The charity is committed to processing data in accordance with its responsibilities under the GDPR and other relevant data protection legislation.

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.
• 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.

General provisions

1. This policy applies to all personal data processed by the charity.
2. The responsible person shall take responsibility for the charity’s ongoing compliance with this policy.
3. The charity has registered with the Information Commissioner’s Office as an organisation that processes personal data.

Lawful, fair, and transparent processing

1. To ensure its processing of data is lawful, fair, and transparent, the charity shall maintain a register of systems, which seeks to be a comprehensive account of both how and why data is processed, and is available on request.
2. The register of systems shall be reviewed at least annually.
3. Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner.

Lawful purposes

1. All data processed by the charity 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).
2. The charity shall note the appropriate lawful basis in the register of systems.
3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
4. 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 charity’s systems.
5. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. In broad terms our legitimate interest is fulfilling the charitable purpose of Re-engage, which involves sending information to our supporters, contacting our volunteers to plan and administrate activities, taking steps to ensure and monitor compliance with our legal obligations and internal standards and procedures, assessing suitability of volunteers for potential roles and keeping records of volunteer activities and performance.

Data minimisation

1. The charity shall ensure that personal data are adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.

Accuracy

1. The charity shall take reasonable steps to ensure personal data is accurate.
2. 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.

Retention / removal

1. To ensure that personal data is kept for no longer than necessary, the charity shall put in place a data retention policy for each area in which personal data is processed and review this process annually.
2. The data retention policy shall consider what data should / must be retained, for how long, and why.
3. The data retention policy is available on request.

Security

1. The charity shall ensure that personal data is stored securely using modern software that is kept up to date.
2. Access to personal data is limited to personnel who need access based on role and hierarchy. Appropriate electronic security including limited access and password protections are in place to avoid unauthorised sharing of information.
3. Digital data stored in the new system will be subject to Microsoft strict security protocols.
4. When personal data is deleted, this should be done safely such that the data is irrecoverable.
5. Appropriate back-up and disaster recovery solutions shall be in place as detailed in the separate back-up and disaster recovery procedures. These procedures are available on request.

Breach

In the event of a data breach, the relevant person who discovers it will report the matter to the responsible person, who will ensure that steps are taken (i) to recover any lost data, (ii) to assess the potential adverse consequences, including in particular the risk to people’s rights and freedoms, (iii) to limit any damage, (iv) to investigate the breach and identify any faults requiring remedial action, and (v) if appropriate, to notify the Information Commissioner’s Office, unless satisfied that the breach is unlikely to result in a risk to the rights and freedoms of natural persons. Notification must be in accordance with Article 33 of the GDPR (where feasible within 72 hours of its discovery). Further, GDPR Art 33(5) requires the controller to document any personal data breaches.

Procedures associated with this document

• Cookie policy
• Data retention policy
• Register of systems

Monitoring and review process

1. This policy and procedure will be reviewed every year in conjunction with senior managers, and where appropriate amendments will be made having been agreed by the board of trustees. Where review is necessary due to legislative change this will happen immediately.