Wymondham Heritage Society

Data Protection Policy

Definitions

1. Data protection principles

The Society is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

1. processed lawfully, fairly and in a transparent manner in relation to individuals;
2. 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;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. 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;
5. 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
6. 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

1. This policy applies to all personal data processed by the Society.
2. The Responsible Person shall take responsibility for the Society’s ongoing compliance with this policy.
3. This policy shall be reviewed every three years.
4. The Society is not required to register with the Information Commissioner’s Office (“ICO”) as an organisation that processes personal data as it is established “not for profit”.

3. Lawful, fair and transparent processing

1. To ensure its processing of data is lawful, fair and transparent, the Society shall maintain a Purpose Register.
2. The Register shall be reviewed at least every three years.
3. Individuals have the right to access their personal data and any such requests made to the Society shall be dealt with in a timely manner.

4. Lawful purposes

1. All data processed by the Society must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests
2. The Society shall note the appropriate lawful basis in the Purpose Register.
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 Society’s systems.

5. Responsibility

Each team that handles 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

1. The Executive Committee is ultimately responsible for ensuring that the Society meets its legal obligations
2. The Secretary of the Society in respect of the Executive Committee and the Chair person of each sub-committee in respect of their respective sub-committees shall keep records of the names and contact details of their members.
3. The Steward Manager, Tea Room Manager and Maintenance Manager shall keep records of the names and contact details of their volunteers.
4. The Membership Secretary shall keep records of the names and contact details of the members of the Society.

6. Data minimisation

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

7. Accuracy

1. The Society 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.

8. Archiving / removal

1. To ensure that personal data is kept for no longer than necessary, the Society has put in place an archiving policy for each area in which personal data is processed and review this process every three years.
2. The archiving policy requires data to be deleted from records within three months when
   1. A member of the Society’s committees ceases to be a member
   2. A steward, helper or volunteer working in any capacity for the Society ceases to hold such a position
   3. A member of the Society ceases to be a member UNLESS they confirm in writing that they wish their name and contact details to be retained

9. Security

1. The Society shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
3. When personal data is deleted this should be done safely such that the data is irrecoverable.
4. Appropriate back-up solutions shall be in place.

10. Breach

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 Society shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO.

Purpose Register

Purpose/ activity, type of data and lawful basis for processing

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

End of Policy