DATA PROTECTION POLICY
Supporting children with Special Educational Needs in Norfolk and Suffolk
Data Protection Policy
|Charity||means Silver Birch Children’s Trust, a registered charity, No: 1175667. Registered address: 3, Cambridge Road, LONDON, SW20 0SQ|
|GDPR||means the General Data Protection Regulation, May 2018|
|Responsible Person||means David Moat, who acts as Data Protection Officer for the Charity. He can be contacted at email@example.com|
|Register of Systems||means a register of all systems or contexts in which personal data is processed by the Charity.|
1. Data protection principles
The Charity is committed to processing data in accordance with its responsibilities under the GDPR.
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; and
- 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.
2. General provisions
- This policy applies to all personal data processed by the Charity.
- The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
- The Charity shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
- To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.
- The Register of Systems shall be reviewed at least annually.
- Individuals have the right to access their personal Requests to view personal data held can be sent to firstname.lastname@example.org
- Individuals can request that the Charity corrects and/or removes inaccurate data.
- Individuals can request that personal data is not held electronically.
4. Lawful purposes
- The Charity has a legitimate interest in keeping and processing certain data to enable Trustees to communicate with applicants, to consider applications, and for statistical analysis.
5. Data minimisation
- 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.
- The Charity 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.
7. Archiving / removal
- Personal data is kept for the purposes of communication with applicants, consideration of applications, and statistical analysis.
- Personal data may be retained for a period as determined by statutory obligations, but will be removed as soon as reasonably possible.Such data will be anonymised.
- The Charity shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
- Access to personal data shall be limited to Trusteesand appropriate security should be in place to avoid unauthorised sharing of information.
- When personal data is deleted this should be done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions shall be in place.
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, the Charity shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the Information Commissioner’s Office.
END OF POLICY
This version: 5thJuly 2018
Created by: David Moat, Data Protection Officer, Silver Birch Children’s Trust
Review date: July 2019
Silver Birch Children’s Trust
c/o 1 Whinfell Close
LONDON SW16 1Q
Reg. Charity No.
The Silver Birch Children's Trust
2018 © The Silver Birch Trust – All Rights Reserved