Data Protection Policy

 

Avon Valley Dementia Support

Data Protection Policy

 

 

Scope of the policy

This policy applies to the work of Avon Valley Dementia Support (AVDS). The policy sets out the requirements that AVDS has to gather information. The policy details how personal information will be gathered, stored and managed in line with data protection principles and the General Data Protection Regulation. The policy is reviewed on an ongoing basis by AVDS committee members to ensure that we are compliant. This policy should be read in tandem with AVDS’s Privacy Policy.

This data protection policy ensures AVDS:

• Complies with data protection law and follows good practice

• Protects the rights of beneficiaries and volunteers

• Is open about how it stores and processes data

• Protects itself from the risks of a data breach

General guidelines for committee members and group leaders

• The only people able to access data covered by this policy should be those who need to communicate with or provide a service to the beneficiaries and volunteers of AVDS.

• AVDS will provide induction training to committee members and group leaders to help them understand their responsibilities when handling data.

• Committee Members and group leaders should keep all data secure, by taking sensible precautions and following the guidelines below.

• Strong passwords must be used and they should never be shared.

• Data should not be shared outside AVDS unless with prior consent and/or for specific and agreed reasons. Examples where data could be shared would include Gift Aid information provided to HMRC.

• Personal data should be refreshed periodically to ensure accuracy.

The General Data Protection Regulation identifies key data protection principles:

Principle 1 - Personal data shall be processed lawfully, fairly and in a transparent manner

Principle 2 - Personal data must be 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.

Principle 3 - The collection of personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

Principle 4 – Personal data held should be 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 purposes for which they are processed, are erased or rectified without delay;

Principle 5 – Personal data must kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for the 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 organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals;

Principle 6 - Personal data must be processed in accordance a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Lawful, fair and transparent data processing

Forms used to request personal information will contain a privacy statement with reasons why the information is being requested and what the information will be used for.

Avon Valley Dementia Support will ensure that members' information is managed in such a way as to not infringe an individual members rights which include:

• The right to be informed

• The right of access

• The right to rectification

• The right to erasure

• The right to restrict processing

• The right to data portability

• The right to object

Adequate, relevant and limited data processing

Avon Valley Dementia Support will only ask for information that is relevant for the provision of support and activities. This will include:

         Name

         Postal address

         Email address

         Telephone numbers

         Health information

         Emergency contact details

Photographs

Photographs are classified as personal data. Where group photographs are being taken members will be asked to step out of shot if they don’t wish to be in the photograph. Otherwise, consent will be obtained in order for photographs to be taken and those in the photographs will be informed as to where photographs will be displayed. Should a member wish at any time to remove their consent and to have their photograph removed then they should contact the AVDS committee to advise them that they no longer wish their photograph to be displayed.

Accuracy of data and keeping data up-to-date

Avon Valley Dementia Support has a responsibility to ensure information is kept up to date.

Accountability and governance

The AVDS Committee are responsible for ensuring that the AVDS remains compliant with data protection requirements and can evidence that it has. Where consent is required for specific purposes then evidence of this consent (either electronic or paper) will be obtained and retained securely. The AVDS Committee will ensure that new members joining the Committee receive an induction into the requirements of GDPR and the implications for their role. AVDS will also ensure that group leaders are made aware of their responsibilities in relation to the data they hold and process. Committee Members shall also stay up to date with guidance and practice. The Committee will review data protection and who has access to information on a regular basis as well as reviewing what data is held. When Committee Members and group leaders relinquish their roles, they will be asked to either pass on data to those who need it and/or delete data.

Secure Processing

AVDS Committee Members have a responsibility to ensure that data is both securely held and processed. This will include:

• Committee members using strong passwords

• Committee members not sharing passwords

• Restricting access of sharing member information to those on the Committee who need to communicate with beneficiaries and volunteers on a regular basis

• Using password protection on laptops and PCs that contain personal information

• Using password protection or secure cloud systems when sharing data between committee members and/or group leaders

Subject Access Request

Beneficiaries and volunteers are entitled to request access to the information that is held by AVDS. The request needs to be received in the form of a written request to the Secretary of AVDS. On receipt of the request, the request will be formally acknowledged and dealt with expediently (the legislation requires that information should generally be provided within one month) unless there are exceptional circumstances as to why the request cannot be granted. AVDS will provide a written response detailing all information held on the member. A record shall be kept of the date of the request and the date of the response.

Data Breach Notification

Were a data breach to occur action shall be taken to minimise the harm. This will include ensuring that all AVDS Committee Members are made aware that a breach has taken place and how the breach occurred. The Committee shall then seek to rectify the cause of the breach as soon as possible to prevent any further breaches. Where necessary, the Information Commissioner's Office would be notified. The Committee shall also contact the relevant beneficiaries and volunteers to inform them of the data breach and actions taken to resolve the breach.