Data Protection Policy

Context and overview

Introduction

Inspire Young People needs to gather and use certain information about individuals.

These can include customers, suppliers, volunteers, business contacts, employees 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 charity’s data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures Inspire:

  • Complies with data protection law and follow good practice
  • Protects the rights of volunteers, staff, customers and partners
  • 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 Inspire — 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. These say 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
  1. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

People, risks and responsibilities

Policy scope

This policy applies to:

  • All Trustees, staff and volunteers of Inspire
  • All contractors, suppliers and other people working on behalf of Inspire

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
  • …plus any other information relating to individuals

Data protection risks

This policy helps to protect Inspire 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 for or with Inspire has some responsibility for ensuring data is collected, stored and handled appropriately.

Anyone who handles personal data must ensure that it is handled and processed in line with this policy and 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.
  • All date should be kept, 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.

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the data controller.

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.
  • paper and printouts should not be 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.
  • If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
  • Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
  • Servers containing personal data should be sited in a secure location, away from general office space.
  • Data should be backed up frequently. Those backups should be tested regularly, in line with the charity’s standard backup procedures.
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
  • All servers and computers containing data should be protected by approved security software and a firewall.

Data use

Personal data is of no value to Inspire 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, employees 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. The IT manager can explain how to send data to authorised external contacts.
  • Personal data should never be transferred outside of the European Economic Area.
  • Copies of personal data should not be saved to personal computers. Always access and update the central copy of any data.

Data accuracy

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

The more important it is that the personal data is accurate, the greater the effort Inspire should put into ensuring its accuracy.

It is the responsibility of all 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. Staff should not create any unnecessary additional data sets.
  • Every opportunity should be taken to ensure data is updated. For instance, by confirming a contact’s details when they call.
  • Data should be updated as inaccuracies are discovered. For instance, if a contact 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 Inspire 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 charity is meeting its data protection obligations.

If an individual contacts the charity 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, Pauline Odulinski. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 per subject access request. 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, Inspire will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the charity’s legal advisers where necessary.

 

December 2017