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Data Protection Policy

Context and Overview

Key details

  • Policy prepared by: Administration Team
  • Approved by board/management on: 16th July 2018
  • Policy will become operational: 25th May 2018
  • Next review date January 2019

Introduction

German Shepherd Rescue South (GSRS) is a registered charity based in Hampshire that rescues and rehomes unwanted, tray and abused German Shepherds. To carry out this work it needs to gather and use certain information about individuals.

These can include potential adopters, fosterers, suppliers, business contacts, volunteers and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the current legislation surrounding Data Protection including the General Data Protection Regulations which can into effect on 25th May 2018

Why this policy exists

This data protection policy ensures GSRS:

  • Complies with data protection law and follows good practice
  • Protects the rights of all volunteers working for the benefit of the charity
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risks of a data breach

Data Protection Law

The Data Protection Act 1998 describes how organisations -including GSRS must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the Law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles which state that personal data must:

  1. Be processed fairly and lawfully
  2. Be obtained only for specific, lawful purposes
  3. Be adequate, relevant and not excessive
  4. Be accurate and kept up to date
  5. Not be held for any longer than necessary
  6. Processed in accordance with the rights of data subjects
  7. Be protected in appropriate ways
  8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

Policy Scope

This policy applies to:

  • All volunteers working on behalf of GSRS
  • All contractors, suppliers and other people working on behalf of GSRS

It applies to all data that the charity holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers

Data protection risks

This policy helps to protect GRS from some very real data security risks including:

  • Breaches of confidentiality. For instance, information being given out inappropriately.
  • Failing to offer choice. For instance, all individuals should be free to choose how the charity uses data relating to them.
  • Reputational damage. For instance, the charity could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works on behalf of GSRS has a responsibility for ensuring data is collected, stored and handled appropriately.

All members of the admin team who handle personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

Carol Middleton acts as Data Protection Officer as is responsible for:

  • Keeping the admin team and other volunteers updated about data protection responsibilities, risks and issues
  • Reviewing all data protection procedures and related policies, in line with an agreed schedule
  • Arranging data protection training and advice for the people covered by this policy
  • Handling data protection questions from anyone covered by this policy
  • Dealing with requests from individuals to see the data GSRS holds about them (also called ‘subject access requests’).
  • Checking and approving any contracts or agreements with third parties that may handle the charity’s sensitive data.
  • Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
  • Performing regular checks and scans to ensure security hardware and software is functioning properly.
  • Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing
  • services.
  • Approving any data protection statements attached to communications such as emails and letters.
  • Addressing any data protection queries from journalists or media outlets like newspapers.
  • Where necessary, working with other volunteers to ensure marketing initiatives abide by data protection principles.

General Guidelines

  • The only people able to access data covered by this policy should be those who need it for their work.
  • Data should not be shared informally. When access to confidential information is required, volunteers can request it from Carol Middleton.
  • GSRS will provide training to all volunteers to help them understand their responsibilities when handling data.
  • Volunteers should keep all data secure, by taking sensible precautions and following the guidelines below.
  • In particular, strong passwords must be used, and they should never be shared.
  • Personal data should not be disclosed to unauthorised people, either within the charity or externally.
  • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
  • Volunteers should request help from Carol Middleton if they are unsure about any aspect of data protection.

Data Storage

These rules describe how and where data should be safely stored.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

  • When not required, the paper or files should be kept in a locked drawer or filing cabinet.
  • Volunteers should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
  • Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords that are changed regularly and never shared between volunteers.
  • If data is stored on removable media (like a CD, DVD or portable hard drive), these should be kept locked away securely when not being used.
  • Data should only be stored on designated drives and should only be uploaded to an approved cloud computing services.
  • Data should be backed up frequently. Those backups should be tested regularly.
  • Data should never be saved directly to mobile devices like tablets or smart phones. Any data saved to laptops is in encrypted form.
  • All computers containing data should be protected by approved security software and a firewall.

Data use

Personal data is of no value to GSRS unless the charity can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

  • When working with personal data, volunteers should ensure the screens of their computers are always locked when left unattended.
  • Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
  • Data must be encrypted before being transferred electronically.
  • Personal data should never be transferred outside of the European Economic Area.
  • Volunteers should not save copies of personal data to their own computers.

Data accuracy

The law requires GSRS to take reasonable steps to ensure data is kept accurate and up to date.

It is the responsibility of all volunteers who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

  • Data will be held in as few places as necessary. Volunteers should not create any unnecessary additional data sets.
  • Volunteers should take every opportunity to ensure data is updated. For instance, by confirming details when they call.
  • GSRS will make it easy for data subjects to update the information GSRS holds about them via the enquiry form on the charity website.
  • Data should be updated as inaccuracies are discovered.

Subject access requests

All individuals who are the subject of personal data held by GSRS are entitled to:

  • Ask what information the charity holds about them and why.
  • Ask how to gain access to it.
  • Be informed how to keep it up to date.
  • Be informed how the company is meeting it’s data protection obligations
  • Ask to have their details removed from any databases.

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller at enquiries@gsrs.org.uk. The data controller can supply a standard request form, although individuals do not have to use this.

The data controller will aim to provide the relevant data within 14 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies, without the consent of the data subject.

Under these circumstances, GSRS will disclose requested data. However, the data controller will ensure the request is legitimate, seeking legal advice where necessary.

Providing information

GSRS aims to ensure that individuals are aware that their data is being processed, and that they understand:

  • How the data is being used
  • How to exercise their rights

To these ends, the charity has a privacy statement, setting out how data relating to individuals is used by the charity.

A version of this statement is also available on the company’s website

Reporting breaches

All volunteers have an obligation to report actual or potential data protection compliance failures to the data controller Carol Middleton. This allows us to:

Investigate the failure and take remedial steps if necessary.

Monitoring

Everyone must observe this policy. Carol Middleton has overall responsibility for this policy. She will monitor it regularly to make sure it is being adhered to.

Consequences of failing to comply

We take compliance with this policy very seriously. Failure to comply puts both volunteers, and the charity at risk and may result in a volunteer being told that working with the charity is no longer possible.

Review of this Policy

We keep this Policy under regular review. This statement was last updated in June 2018.

GSRS Privacy Statement

At GSRS, we are committed to protecting and respecting your privacy.

This Statement explains when and why we collect personal information about people, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

Who are we?

We are GSRS. We rescue and re-home stray, unwanted and abused German Shepherd across the UK.

How do we collect information from you?

We obtain information about you when you express an interest to adopt or foster one of our dogs or when you make a payment to our charity either in the form of a donation, for the payment of veterinary, kennel or related costs or to purchase merchandise from us.

What information is being collected?

Adopters and Fosterers – names, address, telephone numbers, and email addresses. Volunteers/Donators – names, address, telephone numbers and email addresses.
Customers – Name, address, email address, telephone number, bank details

Who is collecting it?

Volunteers of GSRS.

How is it collected?

By personal contact by our volunteers, from the charity website or via social media, for example Facebook

Why is it being collected and how will it be used?

To enable GSRS to ensure that dogs are re-homed appropriately and enable long term contact to be maintained with dogs who have been adopted and fostered.

To enable payment to be made either for donations to the charity or the purchase of merchandise

Who will it be shared with?

Information will not normally be shared with anyone outside of the charity. In the case of a veterinary emergency or criminal matter it may be necessary to share details with the charity’s nominated veterinary surgery or the local police.

Identity and contact details of any data controllers

Carol Middleton – email: enquiries@gsrs.co.uk

Retention period

Information need will be assessed twice a year or on contact by individuals.

Your Choices

You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us you can select your choices by ticking the relevant boxes situated on the form on which we collect your information.

We will not contact you for marketing purposes by email, phone or text message unless you have given your prior consent. You can change your marketing preferences at any time by contacting us by email enquiries@gsrs.co.uk

How you can access and update your information

The accuracy of your information is important to us. If you change email address, or any of the other information we hold is inaccurate or out of date, please email us at enquiries@gsrs.org.uk or write to us at 48 Edward Grove, Fareham PO16 8JA
You have the right to ask for a copy of the information we hold about you (we will charge £10 for information requests) to cover our costs in providing you with details of the information we hold about you.

Security precautions in place to protect the loss, misuse or alteration of your information

When you give us personal information, we take steps to ensure that it’s treated securely. We will ensure that:

  • Email accounts are only accessed by the owner of that email address and passwords are not shared
  • Documents that are printed are stored securely
  • Documents that are stored electronically are password protected and only accessible to those who are authorised to use that information
  • Information will be destroyed appropriately when no longer needed.