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Data Protection Policy

1. Introduction

The Albion Foundation (hereinafter referred to as “TAF”) recognises and understands that the efficient management of its data and records is necessary to support its core business functions, to comply with its legal, statutory and regulatory obligations, to ensure the protection of personal information and to enable the effective management of the organisation. TAF also recognises that the lawful and correct treatment of information is very important to our successful operation and in maintaining confidence between us and those with whom we carry out business.

TAF adheres to and fully endorses the principles of the General Data Protection Regulations (GDPR).

This policy and related documents meet the standards and expectations set out by contractual and legal requirements and have been developed to meet the best practices of business records management, with the direct aim of ensuring a robust and structured approach to document control and systems.

This policy relates to all relevant individuals with whom TAF processes data either in manual or electronic records. These relevant individuals are defined as – but not restricted to - job applicants, employees, volunteers, self-employed contractors and participants (and/or responsible adults). These are referred to in this policy as relevant adults.

2. DEFINITIONS

“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information (e.g. name, address, telephone number, etc.).

“Special categories of personal data” is information, which relates to an individual’s health, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership.

“Criminal offence data” is data, which relates to an individual’s criminal convictions and offences.

“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

3. DATA PROTECTION PRINCIPLES

Under GDPR, all personal data obtained and held by TAF must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

a. Data processing will be fair, lawful and transparent.

b. Data will be collected for specific, explicit, and legitimate purposes only.

c. Data collected will be adequate, relevant and limited to what is necessary for the purposes of processing.

d. Data will be kept accurate and up to date. Data that is found to be inaccurate will be rectified or erased without delay.

e. Data is not kept for longer than is necessary for its given purpose (see retention schedule).

f. Data will be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures.

g. We will comply with the relevant GDPR procedures for international transferring of personal data.

4. TYPES OF DATA HELD

TAF stores and/or shares several categories of personal data in order to carry out effective and efficient processes. TAF stores employee/volunteer data in a personnel file and within our computer systems, for example, HR software. TAF also stores information on participants (within our CRM/booking software) and shares this with funding agencies (but this is only for the purposes of meeting specific funding criteria).

Specifically, we hold the following types of data:

EMPLOYEES/VOLUNTEERS

a. Personal details such as name, address, phone numbers, etc.

b. Information gathered via the recruitment process.

c. Details relating to pay administration such as National Insurance numbers, bank account details and tax codes.

d. Medical or health information.

e. Information relating to your employment with us (e.g. performance records, disciplinary information, etc.)

PARTICIPANTS

a. Personal details such as name, address, phone numbers, etc.

b. Sensitive information such as medical history, ethnicity, etc.

All of the above information is required for our processing activities. More information on those processing activities is included in our privacy notice.

5. EMPLOYEE RIGHTS

You have the following rights in relation to the personal data we hold on you:

a. The right to be informed about the data we hold on you and what we do with it.

b. The right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”;

c. The right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’.

d. The right to have data deleted in certain circumstances. This is also known as ‘erasure’.

e. The right to restrict the processing of the data.

f. The right to transfer the data we hold on you to another party. This is also known as ‘portability’.

g. The right to object to the inclusion of any information.

h. The right to regulate any automated decision-making and profiling of personal data.

More information can be found on each of these rights in our separate policy on employee rights under GDPR.

6. RESPONSIBILITIES.

In order to protect the personal data of relevant individuals, those within TAF who must process data as part of their role have been made aware of our policies on data protection.

TAF have also appointed employees with responsibility for reviewing and updating our data protection policies and processes.

7. LAWFUL BASES OF PROCESSING.

TAF acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity.

Where no other lawful basis applies, TAF may seek to rely on the individuals consent in order to process data.

However, TAF recognise the high standard attached to its use. We understand that consent must be freely given, specific, informed and unambiguous. Where consent is to be sought, TAF will do so on a specific and individual basis where appropriate. Individuals will be given clear instructions on the desired processing activity, informed of the consequences of their consent and of their clear right to withdraw consent at any time.

8. ACCESS TO DATA

As stated above, individuals have a right to access the personal data that TAF store on them. To exercise this right, individuals should make a ‘Subject Access Request’. TAF will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.

No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the individual making the request. In these circumstances, a reasonable charge will be applied.

9. DATA DISCLOSURES

TAF may be required to disclose certain data/information to any person. The circumstances leading to such disclosures include:

a. Any employee benefits operated by third parties.

b. Disabled individuals - whether any reasonable adjustments are required to assist them at work.

c. Individuals’ health data - to comply with health and safety or occupational health obligations towards an individual.

d. For Statutory Sick Pay purposes.

e. HR management and administration - to consider how an individual’s health affects his or her ability to do their job.

f. The smooth operation of any employee insurance policies or pension plans;

g. To assist law enforcement or a relevant authority to prevent or detect crime or prosecute offenders or to assess or collect any tax or duty.

h. To share individual’s data with funding agencies.

These kinds of disclosures will only be made when strictly necessary for the purpose.

10. DATA SECURITY

All our employees are aware that hard copy personal information should be kept in a locked filing cabinet, drawer, or safe.

Employees are aware of their roles and responsibilities when their role involves the processing of data. All employees are instructed to store files or written information of a confidential nature in a secure manner so that they are only accessed by people who have a need and a right to access them and to ensure that screen locks are implemented on all PCs, laptops etc. when unattended. No files or written information of a confidential nature are to be left where unauthorised people can read them.

Where data is computerised, it should be coded, encrypted or password protected both on a local hard drive and on a network drive that is regularly backed up. If a copy is kept on removable storage media, that media must itself be kept in a locked filing cabinet, drawer, or safe.

Employees must always use the passwords provided to access the computer system and not abuse them by passing them on to people who should not have them.

Personal data relating to employees should not be kept or transported on laptops, USB sticks, or similar devices, unless prior authorisation has been received. Where personal data is recorded on any such device it should be protected by:

a. Ensuring that data is recorded on such devices only where absolutely necessary.

b. Using an encrypted system—a folder should be created to store the files that need extra protection.

c. Ensuring that laptops or USB drives are not left where they can be stolen.

Failure to follow the TAF policy on data security may be dealt with via the TAF’s disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.

11. THIRD PARTY PROCESSING

Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the TAF’s commitment to protecting data.

12. INTERNATIONAL DATA TRANSFERS

The Company does not transfer personal data to any recipients outside of the EEA.

13. REQUIREMENT TO NOTIFY BREACHES

All data breaches will be recorded on our Data Breach Register. Where legally required, TAF will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, TAF will inform the individual whose data was subject to breach.

More information on breach notification is available in our Breach Notification policy.

14. TRAINING

New TAF employees must read and understand the policies on data protection as part of their induction.

All TAF employees must complete an e-training course covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach.

The nominated data controller (Head of Operations) for TAF is trained appropriately in their role under the GDPR.

All TAF employees who need to use relevant computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and the Company of any potential lapses and breaches of the TAF’s policies and procedures.

15. GDPR Compliance

The Data Protection Officer for TAF is Rob Lake and can be contacted at rob.lake@albionfoundation.co.uk.