Introduction

The Derbyshire Children’s Holiday Centre (DCHC) needs to gather and use certain information about individuals. These can include employees, charity users, suppliers, business contacts and other people the organisation has a relationship with or may need to contact. Our 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.

The data protection policy ensures that the DCHC:-

1. Complies with data protection law and follow good practice
2. Protects the rights of staff, customers and partners
3. Is open about how it stores and processes individuals’ data
4. Protects itself from the risks of a data breach                   

Data Protection

The Data Protection Act 2018 describes how organisations including the DCHC 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 2018 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.

Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection.

General Staff Guidelines

The only people able to access data covered by our policy should be those who need it for their work. Data should not be shared informally. When access to confidential information is required, employees can request it from the CEO. The DCHC will provide training to all employees to help them understand their responsibilities when handling data. Trustees, employees and volunteers should keep all data secure, by taking sensible precautions and following the guidelines below:-

1. In particular, strong passwords must be used, and they should never be shared.
2. Personal data should not be disclosed to unauthorised people, either within the company or externally.
3. Data should be regularly reviewed and updated if it is found to be out of date.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.
4. Trustees, employees and volunteers should request help from the CEO if they are unsure about any aspect of data protection.

1. Data Storage

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

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:

1. When not required, the paper or files should be kept in a locked drawer or filing cabinet.
2. Employees should make sure paper, and printouts are not left where unauthorised people could see them, like on a printer.
3. 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:

1. Data should be protected by strong passwords that are changed regularly and never shared between employees.
2. If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
3. Data should only be stored on designated drives and servers and should only be uploaded to an approved cloud computing service.
4. Servers containing personal data should be sited in a secure location, away from general office space.
5. Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
6. Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
7. All servers and computers containing data should be protected by approved security software and a firewall.

1. Data Use

Personal data is of no value to the DCHC unless it can be made use of. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:-

1. When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
2. Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
3. Personal data should never be transferred outside of the European Economic Area.
4. Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data Accuracy

The law requires that the DCHC takes 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 the DCHC should put into ensuring its accuracy. 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.

1. Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
2. Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
3. Data should be updated as inaccuracies are discovered. For instance, if a customer 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 the DCHC are entitled to:

1. Ask what information the charity holds about them and why.
2. Ask how to gain access to it.
3. Be informed how to keep it up to date.
4. Be informed how the charity 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, addressed to the CEO, [email protected]

If needed a standard request form can be supplied although individuals do not have to use this.

The DCHC will aim to provide the relevant data within 14 days. The DCHC (CEO) 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, the DCHC will disclose requested data. However, the CEO will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Providing Information

The DCHC aims to ensure that individuals are aware that their data is being processed, and that they understand:

1. How the data is being used.
2. How to exercise their rights.

To these ends, the DCHC has a privacy statement, setting out how data relating to individuals is used by the DCHC. [This is available on request. A version of this statement is also available on the charity’s website].

Changes to this Privacy Policy

DCHC reserve the right to amend or modify this Privacy Policy at any time and any changes will be published on our website.