Privacy policy

 

Data Protection Policy Statement

Trobs UK collects and uses information about people with whom it communicates. This personal information must be dealt with properly and securely however it is collected, recorded and used – whether on paper, in a computer, or recorded on other material – and there are safeguards to ensure this in the Data Protection Act 1998.

Trobs UK regards the lawful and correct treatment of personal information as very important to the successful and efficient performance of its functions, and to maintain confidence between those with whom it deals.

To this end Trobs UK fully endorses and adheres to the Principles of Data Protection, as set out in the Data Protection Act 1998.

Purpose

The purpose of this policy is to ensure that the Directors and Members of Trobs UK are clear about the purpose and principles of Data Protection and to ensure that it has guidelines and procedures in place which are consistently followed.

Failure to adhere to the Data Protection Act 1998 is unlawful and could result in legal action being taken against Trobs UK or its staff, volunteers or trustees.

Principles

The Data Protection Act 1998 regulates the processing of information relating to living and identifiable individuals (data subjects). This includes the obtaining, holding, using or disclosing of such information, and covers computerised records as well as manual filing systems and card indexes.

Data users must comply with the data protection principles of good practice which underpin the Act. To comply with the law, information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully.

To do this Trobs UK follows the eight Data Protection Principles outlined in the Data Protection Act 1998, which are summarised below:

  1. Personal data will be processed fairly and lawfully
  2. Data will only be collected and used for specified purposes
  3. Data will be adequate, relevant and not excessive
  4. Data will be accurate and up to date
  5. Data will not be held any longer than necessary
  6. Data subject’s rights will be respected
  7. Data will be kept safe from unauthorised access, accidental loss or damage  

VIII. Data will not be transferred to a country outside the European Economic Area, unless that country has equivalent levels of protection for personal data.

The principles apply to “personal data” which is information held on computer or in manual filing systems from which they are identifiable. Trobs UK employees, volunteers and trustees who process or use any personal information in the course of their duties will ensure that these principles are followed at all times.

Procedures

The following procedures have been developed in order to ensure that Trobs UK meets its responsibilities in terms of Data Protection. For the purposes of these procedures data collected, stored and used by Trobs UK falls into 2 broad categories:

1. Trobs UK internal data records; Directors, Members

2. Trobs UK external data records; Members, customers, clients.

Trobs UK as a body is a DATA CONTROLLER under the Act, and the Managing Director is ultimately responsible for the policy’s implementation.

Internal data record

Purposes

Trobs UK obtains personal data (names, addresses, phone numbers, email addresses), application forms, and references and in some cases other documents from Directors and Members. This data is stored and processed for the following purposes:

  • Recruitment
  • Equal Opportunities monitoring
  • To distribute relevant organisational material e.g. meeting papers

Contact details of Directors and Members will not be passed on to anyone outside the organisation without their explicit consent.

A copy of Directors and Members emergency contact details will be kept in the Emergency File for Health and Safety purposes to be used in emergency situations e.g. fire/ bomb evacuations.

Directors and Members will be supplied with a copy of their personal data held by the organisation if a request is made.

All confidential post must be opened by the addressee only.

Accuracy

Trobs UK will take reasonable steps to keep personal data up to date and accurate. Personal data will be stored for 6 years after a Director and Member has worked/registered for the organisation and brief details for longer. Unless the organisation is specifically asked by an individual to destroy their details it will normally keep them on file for future reference. The Director has responsibility for destroying personnel files.

Storage

Personal data is kept in paper-based systems and on a password-protected computer system. Every effort is made to ensure that paper-based data are stored in organised and secure systems.

Trobs UK operates a clear desk policy at all times.

Use of Photographs

Where practicable, Trobs UK will seek consent from individuals before displaying photographs in which they appear. If this is not possible (for example, a large group photo), the organisation will remove any photograph if a complaint is received. This policy also applies to photographs published on the organisations website, via Social Media or in the Newsletter.

External data 

Trobs UK obtains personal data (such as names, addresses, phone numbers and emails) from members/clients. This data is obtained, stored and processed solely to assist staff in the efficient running of services. Personal details supplied are only used to send material that is potentially useful. Most of this information is stored on the organisation’s database.

Trobs UK obtains personal data and information from clients and members in order to provide services. This data is stored and processed only for the purposes outlined in the agreement and service specification signed by the client/ member.

Consent

Personal data is collected over the phone, via web and using other methods such as e-mail. During this initial contact, the data owner is given an explanation of how this information will be used. Written consent is not requested as it is assumed that the consent has been granted when an individual freely gives his or her own details.

Personal data will not be passed on to anyone outside the organisation without explicit consent from the data owner unless there is a legal duty of disclosure under other legislation, in which case the Director will discuss and agree disclosure with the Managing Director. Contact details held on the organisation’s database may be made available to groups/ individuals outside of the organisation. Individuals are made aware of when their details are being collected for the database and their verbal or written consent is requested

Access

Only the organisation’s Directors and Members will normally have access to personal data. All Directors and Members are made aware of the Data Protection Policy and their obligation not to disclose personal data to anyone who is not supposed to have it.

Information supplied is kept in a secure filing, paper and electronic system and is only accessed by those individuals involved in the delivery of the service.

Information will not be passed on to anyone outside the organisation without their explicit consent, excluding statutory bodies e.g. the Inland Revenue.

Individuals will be supplied with a copy of any of their personal data held by the organisation if a request is made.

All confidential post must be opened by the addressee only.

Accuracy

Trobs UK will take reasonable steps to keep personal data up to date and accurate. Personal data will be stored for as long as the data owner/ client/ member uses our services and normally longer. Where an individual ceases to use our services and it is not deemed appropriate to keep their records, their records will be destroyed according to the schedule in Appendix B. However, unless we are specifically asked by an individual to destroy their details, we will normally keep them on file for future reference.

If a request is received from an organisation/ individual to destroy their records, we will remove their details from the database and request that all staff holding paper or electronic details for the organisation destroy them. This work will be carried out by the Managing Director.

This procedure applies if Trobs UK is informed that an organization/individual ceases to exist.

Storage

Personal data may be kept in paper-based systems and on a password-protected computer system. Paper-based data are stored in organised and secure systems.

Trobs UK operates a clear desk policy at all times.

Use of Photographs

Where practicable, Trobs UK will seek consent of members/ individuals before displaying photographs in which they appear. If this is not possible (for example, a large group photo), the organisation will remove any photograph if a complaint is received. This policy also applies to photographs published on the organisation’s website, via Social Media or in the Newsletter.

Responsibilities of Directors and Members.

During the course of their duties with Trobs UK, Directors and Members will be dealing with information such as names/addresses/phone numbers/e-mail addresses of members/clients/volunteers. They may be told or overhear sensitive information while working for Trobs UK. The Data Protection Act (1988) gives specific guidance on how this information should be dealt with. In short to comply with the law, personal information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully. Staff, paid or unpaid must abide by this policy.

To help Directors and Members meet the terms of the Data Protection Act; the attached Data Protection/Confidentiality statement has been produced. Directors and Members are asked to read and sign this statement to say that they have understood their responsibilities as part of the induction programme.

Compliance

Compliance with the Act is the responsibility of all staff, paid or unpaid. Trobs UK will regard any unlawful breach of any provision of the Act by any staff, paid or unpaid, as a serious matter which will result in disciplinary action. Any employee who breaches this policy statement will be dealt with under the disciplinary procedure which may result in dismissal for gross misconduct. Any such breach could also lead to criminal prosecution.

Any questions or concerns about the interpretation or operation of this policy statement should in the first instance be referred to the line manager.

Retention of Data

No documents will be stored for longer than is necessary.

All documents containing personal data will be disposed of securely in accordance with the Data Protection principles.

 

Updated and Revised: June 2015

 

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