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Home in Frome Data Protection Policy
This policy was approved by the full Home in Frome Committee on:
The Policy became operational on: May 25th 2018
It will be reviewed on: May 25th 2019
Home in Frome needs to gather and use certain information about individuals.
These can include service suppliers, business contacts, officers and committee members, friends 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 company's data protection standards and to comply with the law.
Why this policy exists
This data protection policy ensures that Home in Frome:
• Complies with data protection law and follow good practice
• Protects the rights of members and other individuals with whom the society has dealings.
• 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 Home in Frome— 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.
In line with E.U. General Data Protection Regulations, the Data Protection Act is underpinned by eight important principles. The act states 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
This policy applies to:
• The officers and committee of the Home in Frome
• All volunteers working with Home in Frome
• All service suppliers and others working on behalf of Home in Frome
It applies to all data that the company 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
plus any other information relating to individuals for the purpose of administering the Home in Frome’s business.
Data protection risks
This policy helps to protect Home in Frome 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 Home in Frome uses data relating to them.
• Reputational damage. For instance, the Home in Frome could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with Home in Frome has some responsibility for ensuring data is collected, stored and handled appropriately.
Each committee, sub-committee, team or person that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
The following people, however, have key areas of responsibility:
• The Home in Frome Chair is ultimately responsible for ensuring that Home in Frome meets its legal obligations.
• The Home in Frome Chair and Committee are responsible for
i. Keeping the officers and committee updated about data protection responsibilities, risks and issues.
ii. Reviewing all data protection procedures and related policies, in line with an agreed schedule.
iii. Arranging data protection advice for the people covered by this policy.
iv. Handling data protection questions from members and anyone else covered by this policy.
v. Dealing with requests from individuals to see the data Home in Frome holds about them (also called 'subject access requests').
vi. Checking and approving any contracts or agreements with third parties that may handle the company's sensitive data.
• The Home in Frome Committee is responsible for:
I. Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
II. Performing regular checks and scans to ensure security hardware and software is functioning properly.
III. Evaluating any I.T. services the company is considering using to store or process data, for instance, cloud computing services and website provider.
IV. Approving any data protection statements attached to communications such as emails and letters.
V. Addressing any data protection queries from journalists or media outlets like newspapers.
VI. Where necessary, working with other committee members to ensure that promotional and publicity initiatives abide by data protection principles.
VII. Ensuring that information sent out in the course of their particular role/job does not disclose other members’ personal data unless this has previously been approved.
VIII. Ensuring that members’ personal data is collected, stored and handled appropriately.
• The Home in Frome Treasurer is responsible for:
I. Collecting, processing and storing data in relation to Home in Frome finances.
The only people able to access data covered by this policy should be those who need it to complete the tasks related to their particular role
Data should not be shared informally.
When access to confidential information is required, this must be given on a strictly ‘need to know’ basis.
• Home in Frome Committee will provide advice to all officers and members to help them understand their responsibilities when handling data.
• Officers and committee members should keep all data secure, by taking sensible precautions and following the guidelines below.
i. Strong passwords must be used and should never be shared.
ii. Personal data should not be disclosed to unauthorised people, either within Home in Frome or externally.
iii. Data should be regularly reviewed and updated. If it is found to be out of date or if no longer required, it should be deleted and disposed of.
iv. Members should request help from the data protection officer if they are unsure about any aspect of data protection.
• These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the HIF Committee.
I. When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
II. These guidelines also apply to data that is usually stored electronically but which has, for some reason, been printed out.
III. When not required, the paper or files should be kept in a secure place.
IV. Paper and printouts should not be left where unauthorised people could see them.
V. Data printouts should be shredded and disposed of securely when no longer required.
VI. When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
VII. Data should be protected by strong passwords that are changed regularly and never shared between employees.
VIII. Data should be backed up frequently.
i. When working with personal data, officers and committee members should ensure the screens of their computers are always locked when left unattended, if the space is shared with anyone else.
ii. Personal data should not be shared informally.
iii. Data must be encrypted before being transferred electronically.*
iv. Personal data should never be transferred outside of the European Economic Area.
v. Members and Committee Members should not save copies of personal data to their own computers. Always access and update the central copy of any data.
*Follow these steps to encrypt an Excel file:
1. Click File > Info > Protect Workbook > Encrypt with Password .
2. Enter a password, and click OK.
3. In the Confirm Password dialog box, re-enter the password you entered previously.
The law requires Home in Frome to take reasonable steps to ensure data is kept accurate and up to date.
It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
• Recommended steps
I. Data will be held in as few places as necessary. Those handling data should not create any unnecessary additional data sets.
II. Those responsible for data should take every opportunity to ensure data is updated, e.g. by asking members annually if their details are still correct
III. Home in Frome will make it as easy as possible for data subjects to update the information Home in Frome holds about them.
IV. Data should be updated as inaccuracies are discovered.
V. If a member can no longer be reached on their stored telephone number, it should be removed from the database.
Subject Access Requests
All individuals who are the subject of personal data held by Home in Frome are entitled to:
• Ask what information the company holds about them and why.
• Ask how to gain access to it.
• Be informed how to keep it up to date.
• Be informed how HIF is meeting its data protection obligations.
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 to the Home in Frome Chair and Committee at: [email protected]
The HIF Chair and Committee will aim to provide the relevant data within 28 days.
The Home in Frome Chair and Committee will always verify the identity of anyone making a subject access request before handing over any information.
DiscIosing 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, Home in Frome will disclose requested data. However, the HIF Chair and Committee will ensure the request is legitimate, seeking assistance from the chair and officers and from legal advisers where necessary.
Home in Frome 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 Home in Frome has a privacy statement*, setting out how data relating to individuals is used by the society.
*This is available on request and a version of the privacy statement is also available on the Home in Frome’s website.