Data Protection
policy
Sutton Coldfield Angling Trust (the Club) is
committed to being transparent about how it collects and uses the personal data
of its workforce, and to meeting its data protection obligations. This policy
sets out the Club's commitment to data protection, and individual rights and
obligations in relation to personal data.
This policy applies to the personal data of members
and former members, referred to as HR-related personal data.
The Club has appointed Andy Hales, Secretary, as the person with
responsibility for data protection compliance within the Club. He/she can be
contacted at secretaryscas47@gmail.com Questions about this policy, or requests for
further information, should be directed to him.
Definitions
"Personal data" is any information
that relates to an individual who can be identified from that information.
Processing is any use that is made of data, including collecting, storing,
amending, disclosing or destroying it.
"Special categories of personal
data" means information about an individual's racial or ethnic origin,
political opinions, religious or philosophical beliefs, trade union membership,
health, sex life or sexual orientation and biometric data.
Data protection principles
The Club is committed to the principles of the GDPR
and processes personal data in accordance with the following data protection
principles:
- The Club
processes personal data lawfully, fairly and in a transparent manner.
- The Club
collects personal data only for specified, explicit and legitimate
purposes.
- The Club
processes personal data only where it is adequate, relevant and limited to
what is necessary for the purposes of processing.
- The Club
keeps accurate personal data and takes all reasonable steps to ensure that
inaccurate personal data is rectified or deleted without delay.
- The Club
keeps personal data only for the period necessary for processing.
- The Club
adopts appropriate measures to make sure that personal data is secure, and
protected against unauthorised or unlawful processing, and accidental
loss, destruction or damage.
The Club tells individuals the reasons for
processing their personal data, how it uses such data and the legal basis for
processing in its privacy notices. It will not process personal data of
individuals for other reasons.
Where the Club processes special categories of
personal data to perform obligations or to exercise rights in employment law,
this is done in accordance with the requirements of the GDPR and the provisions
set out in this policy.
The Club will update HR-related personal data
promptly if an individual advises that his/her information has changed or is
inaccurate.
Personal data gathered during the memberships is
held in the individual's personnel file (in hard copy or electronic format, or
both), and on HR systems. The periods for which the Club holds HR-related
personal data are for as long as they remain members.
The Club keeps a record of its processing
activities in respect of HR-related personal data in accordance with the
requirements of the General Data Protection Regulation (GDPR).
Individual rights
As a data subject, individuals have a number of
rights in relation to their personal data.
Subject access requests
Individuals have the right to make a subject access
request. If an individual makes a subject access request, the Club will tell
him/her:
- whether
or not his/her data is processed and if so why, the categories of personal
data concerned and the source of the data if it is not collected from the
individual;
- to
whom his/her data is or may be disclosed, including to recipients located
outside the European Economic Area (EEA) and the safeguards that apply to
such transfers;
- for
how long his/her personal data is stored (or how that period is decided);
- his/her
rights to rectification or erasure of data, or to restrict or object to
processing;
- his/her
right to complain to the Information Commissioner if he/she thinks the Club
has failed to comply with his/her data protection rights; and
- whether
or not the Club carries out automated decision-making and the logic
involved in any such decision-making.
The Club will also provide the individual with a
copy of the personal data undergoing processing. This will normally be in
electronic form if the individual has made a request electronically, unless
he/she agrees otherwise.
To make a subject access request, the individual
should send the request to secretaryscas47@gmail.com. In some cases,
the Club may need to ask for proof of identification before the request can be
processed. The Club will inform the individual if it needs to verify his/her
identity and the documents it requires.
The Club will normally respond to a request within
a period of one month from the date it is received. In some cases, such as
where the Club processes large amounts of the individual's data, it may respond
within three months of the date the request is received. The Club will write to
the individual within one month of receiving the original request to tell
him/her if this is the case.
If a subject access request is manifestly unfounded
or excessive, the Club is not obliged to comply with it. Alternatively, the Club
can agree to respond but will charge a fee, which will be based on the
administrative cost of responding to the request. A subject access request is
likely to be manifestly unfounded or excessive where it repeats a request to
which the Club has already responded. If an individual submits a request that
is unfounded or excessive, the Club will notify him/her that this is the case
and whether or not it will respond to it.
Other rights
Individuals have a number of other rights in
relation to their personal data. They can require the Club to:
·
rectify inaccurate data;
- stop
processing or erase data that is no longer necessary for the purposes of
processing;
- stop
processing or erase data if the individual's interests override the Club's
legitimate grounds for processing data (where the Club relies on its
legitimate interests as a reason for processing data);
- stop
processing or erase data if processing is unlawful; and
- stop
processing data for a period if data is inaccurate or if there is a
dispute about whether or not the individual's interests override the Club's
legitimate grounds for processing data.
To ask the Club to take any of these steps, the
individual should send the request to secretaryscas47@gmail.com.
Data security
The Club takes the security of HR-related personal data seriously. The Club
has internal policies and controls in place to protect personal data against
loss, accidental destruction, misuse or disclosure, and to ensure that data is
not accessed, except by employees in the proper performance of their duties.
Where the Club engages third parties to process
personal data on its behalf, such parties do so on the basis of written
instructions, are under a duty of confidentiality and are obliged to implement
appropriate technical and organisational measures to ensure the security of
data.
Data breaches
If the Club discovers that there has been a breach of
HR-related personal data that poses a risk to the rights and freedoms of
individuals, it will report it to the Information Commissioner within 72 hours
of discovery. The Club will record all data breaches regardless of their
effect.
If the breach is likely to result in a high risk to the rights and
freedoms of individuals, it will tell affected individuals that there has been
a breach and provide them with information about its likely consequences and
the mitigation measures it has taken.
Individual responsibilities
Individuals are responsible for helping the Club
keep their personal data up to date. Individuals should let the Club know if
data provided to the Club changes, for example if an individual moves’ house or
changes his/her bank details.
Individuals who have access to personal data are
required:
- to
access only data that they have authority to access and only for
authorised purposes;
- not
to disclose data except to individuals (whether inside or outside the Club)
who have appropriate authorisation;
- to
keep data secure (for example by complying with rules on access to
premises, computer access, including password protection, and secure file
storage and destruction);
- not
to remove personal data, or devices containing or that can be used to
access personal data, from the Club's premises without adopting
appropriate security measures (such as encryption or password protection)
to secure the data and the device; and
- not
to store personal data on local drives or on personal devices that are
used for work purposes.