Data Protection Policy
- Policy prepared by: Helen Hanbury
- Approved by Board/committee on: September 16, 2018
- Next review date: September 2020
Hertfordshire Community Nurses’ Charity (HCNC) is a Charitably Incorporated Organisation ( CIO). In order for it to operate, it needs to gather, store and use certain forms of information about individuals. These can include Trustees, employees, tenants, contractors, previous grant applicants and potential grant applicants, and other people the CIO has a relationship with or regularly needs to contact. This policy explains how this data should be collected, stored and used in order to meet Hertfordshire Community Nurses’ Charity’s data protection standards and comply with the General Data Protection Regulations (GDPR).
Why is this policy important?
This policy ensures that Hertfordshire Community Nurses’ Charity
- Protects the rights of our Trustees, applicants and grant recipients etc
- Complies with data protection law and follows good practice
- Protects the CIO from the risks of a data breach
Who and what does this policy apply to?
This policy applies to all those handling data on behalf of Hertfordshire Community Nurses’ Charity:
That is all Trustees.
It applies to all data that Hertfordshire Community Nurses’ Charity holds relating to individuals, including:
- Date of Birth
- Email addresses
- Postal addresses
- Phone numbers
- Any other personal information held (e.g. financial)
Roles and responsibilities
Hertfordshire Community Nurses’ Charity is the Data Controller and the Trustees act as Data Controllers in common. They will determine what data is collected and how it is used.
The person responsible for Data Protection for HCNC is Helen Hanbury. She, together with the Trustees, is responsible for the secure, fair and transparent collection and use of data by HCNC. Any questions relating to the collection or use of data should be directed to the Data Protection Officer. Everyone who has access to data as part of HCNC has a responsibility to ensure that they adhere to this policy. HCNC uses third party Data Processors (eg. Website administrators – currently Amba Design) to process data on its behalf. HCNC will ensure all Data Processors are compliant with GDPR.
Data Protection Principles
a) We fairly and lawfully process personal data in a transparent way.
HCNC will only collect data where lawful and where it is necessary for the legitimate purposes of the CIO.
- A Trustee’s name and contact details will be collected when they first join HCNC , and will be used to contact the Trustee regarding meetings, administration, and other activities related to the running of the CIO.
- The name and contact details of contractors will be collected when they are first contacted, and will be used to contact them regarding the CIO’s administration related to the jobs they are being hired for. Further information, including personal financial information and criminal records information, may also be collected in specific circumstances where lawful and necessary (in order to process payment to the person or receive assurances of DBS status).
- Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to HCNC’s completing tasks expected as part of working with the individuals).
- A grant applicant’s name and contact details will be collected when they make an application for a grant. This will be used to contact them about their application. Further information, including personal financial information may also be collected in specific circumstances where lawful and necessary (in order to process payment to the person).
- Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to HCNC completing tasks expected as part of the application if successful).
- An individual’s name, contact details and other details may be collected at any time with their consent, in order for HCNC to communicate with them about relevant activities. See ‘How we get consent’ below.
- Lawful basis for processing this data: Consent (see ‘How we get consent’)
b) How we get consent.
Consent to collect and store data will requested on first contact with HCNC. The Data Protection Act Consent Form can be found on the website.
c) We only collect and use personal data for specific, explicit and legitimate purposes and will only use the data for those specified purposes.
When collecting data, HCNC will always provide a clear and specific privacy statement explaining to the subject why the data is required and what it will be used for.
d) We ensure any data collected is relevant and not excessive.
HCNC will not collect or store more data than the minimum information required for its intended purpose. E.g. we need to collect e-mail addresses from applicants in order to be able to contact them about the grant application and administration, but no unnecessary data such as marital status will be collected.
e) We ensure data is accurate and up-to-date.
HCNC will ask Trustees to check and update their data on an annual basis. Any individual will be able to update their data at any point by contacting the Data Protection Officer.
f) We ensure data is not kept longer than necessary.
HCNC will keep records for no longer than is necessary in order to meet the intended use for which it was gathered (unless there is a legal requirement to keep records).
The storage and intended use of data will be reviewed in line with HCNC’s data retention policy. When the intended use is no longer applicable (e.g. contact details for an applicant over 10 years), the data will be deleted within a reasonable period.
g) We will keep personal data secure.
HCNC will ensure that data held by us is kept secure.
- Electronically-held data will be held within a password-protected and secure environment
- Physically-held data (e.g. Letters or email sign-up sheets) will be stored in a locked cupboard
- Access to data will only be given to relevant trustees/committee members/contractors where it is clearly necessary for the running of the CIO. The Data Protection Officer will decide in what situations this is applicable and will keep a master list of who has access to data
h) Transfer to countries outside the EEA.
HCNC will not transfer data to countries outside the European Economic Area (EEA).
When HCNC collects, holds and uses an individual’s personal data, that individual has the following rights over that data. HCNC will ensure its data processes comply with these rights and will make all reasonable efforts to fulfil requests from an individual in relation to those rights.
- Right to be informed: whenever HCNC collects data it will provide a clear and specific privacy statement explaining why it is being collected and how it will be used.
- Right of access: individuals can request to see the data HCNC holds on them and confirmation of how it is being used. Requests should be made in writing to the Data Protection Officer and will be complied with free of charge and within one month. Where requests are complex or numerous this may be extended to two months
- Right to rectification: individuals can request that their data be updated where it is inaccurate or incomplete. HCNC will request that Trustees and contractors check and update their data on an annual basis. Any requests for data to be updated will be processed within one month.
- Right to object: individuals can object to their data being used for a particular purpose. Where we receive a request to stop using data, we will comply unless we have a lawful reason to use the data for legitimate interests or contractual obligation.
- Right to erasure: individuals can request for all data held on them to be deleted. HCNC’s data retention policy will ensure data is not held for longer than is reasonably necessary in relation to the purpose it was originally collected. If a request for deletion is made we will comply with the request unless:
- There is a lawful reason to keep and use the data for legitimate interests or contractual obligation.
- There is a legal requirement to keep the data.
- Right to restrict processing: individuals can request that their personal data be ‘restricted’ – that is, retained and stored but not processed further (e.g. if they have contested the accuracy of any of their data, HCNC will restrict the data while it is verified).
- Right to data portability: Though unlikely to apply to the data processed by HCNC, we will ensure that rights related to portability of data is compliant with GDPR .
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