Data protection policy
The Shrimala Trust
means the General Data Protection Regulation.
person responsible for data protection within the Trust
Register of Systems
means a register of all systems or contexts in which personal data is processed by the Trust, relating to all instances of collection and handling of data. This includes student support, mailing list management, events team, Hermitage management and local group leaders
- Data protection principles
The Trust is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
- “processed lawfully, fairly and in a transparent manner in relation to individuals.
- 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.
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- 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 purpose for which they are processed, are erased or rectified without delay;
- 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 organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.”
- General Provisions
- This policy applies to all personal data processed by the Trust.
- The responsible person shall take responsibility for the Charity’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
- Lawful, fair and transparent processing
- To ensure its processing of data is lawful, fair and transparent, the Trust shall maintain a Register of Systems.
- The Register of Systems shall be reviewed annually.
- Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner.
- Lawful purposes
- All data processed by the Trust must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests
(See ICO guidance for more information)
- The Trust shall note the appropriate lawful basis in the Register of Systems.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
- 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 Trust’s systems.
- Data minimization
- The Trust shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- The Trust will not hold data other than basic contact details and anything relevant to enabling participants to participate in an event that they have booked.
- The Trust will take reasonable steps to ensure personal data is accurate.
- 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.
- To ensure that personal data is kept for no longer than necessary, the Trust shall put in place an archiving policy for each are in which personal data is processed and review this process annually.
- The archiving policy shall consider what data should/must be retained, for how long, and why.
- The Trust shall ensure that personal data is stored securely using modern software that is kept up to date.
- Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorized sharing of information.
- When personal data is deleted this should be done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions shall be in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, access to, personal data, the Charity shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO. (more information on the ICO website).