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Data Protection

FRIENDS OF IMPERIAL SQUARE AND GARDENS (FISG)

including

FRIENDS OF IMPERIAL SQUARE HERITAGE AND CONSERVATION (FISHAC)

 

DATA PROTECTION POLICY

PURPOSE

The purpose of the Policy is to ensure that the organisations, FRIENDS OF IMPERIAL SQUARE AND GARDENS (FISG) and FRIENDS OF IMPERIAL SQUARE HERITAGE AND CONSERVATION (FISHAC), comply with the law and best practice in respect of the personal data held by FISG and FISHAC relating to its members.

SCOPE

The Policy has been adopted by FISG and FISHAC and is adhered to by all Trustees, Directors and honorary officials of FISG and FISHAC.

PRINCIPLES

The principles of data protection contained within the Policy ensure that personal information relating to members held by Trustees, Directors and honorary officials is held fairly and lawfully and for defined purposes and that it

(i)            is adequate, relevant and not excessive

(ii)          is accurate and up to date

(iii)         is not retained longer than is appropriate

(iv)        is used in accordance with the aims and objectives of FISG and FISHAC

(v)          recognizes the rights of the individual to whom the data relates

(vi)        is secure

(vii)     is not transferred to third parties without the express permission of the individual to whom the personal data relates

 

APPLICATION

The Policy applies to personal information relating to identifiable individuals, even if such data is deemed to be outside the scope of relevant data protection legislation by virtue of it not meeting the strict definition of ‘data’ within such legislation.

POLICY

FISG and FISHAC

(i)            comply with both the law and best practice

(ii)          respect the rights of individuals

(iii)         are open and honest with individuals for whom data is held

(iv)        provide appropriate training and support to Trustees, Directors and honorary officials

FISG and FISHAC have identified the following potential key risks to the protection of data and have put in place procedures to ensure such risks are minimised

(i)            breach of confidentiality through information being given out inappropriately.

(ii)          insufficient clarity about the range of uses to which data will be put which may lead to individuals being insufficiently informed

(iii)         breach of security by permitting unauthorised access to personal data

(iv)        failure to establish a robust system of managing changes to personal data leading to such data being out-of-date

(v)          potential reputational damage if personal data is not current

RESPONSIBILITIES

The honorary officials of FISG and the board of Trustees/Directors and honorary officials of FISHAC are responsible for ensuring that FISG and FISHAC comply with their legal obligations and, insofar as this specific policy is concerned, the specific provisions of current data protection legislation in the United Kingdom.

The Data Protection Officer of FISG and FISHAC is the honorary administrative secretary of FISG and FISHAC.

The Data Protection Officer

(i)            maintains the Policy and related data protection procedures

(ii)          ensures the Policy reflects current legislative requirements and best practice

(iii)         ensures the Trustees, Directors and honorary officials are fully aware of their responsibilities for data protection as outlined in the Policy

(iv)        reacts promptly to legitimate requests to access personal data held in respect of that individual

 

DATA PROTECTION PROCEDURES

Personal data in relation to members of FISG and FISHAC is held securely in both electronic and paper forms by the honorary administrative secretary of FISG and FISHAC. Trustees, Directors and other honorary officials of FISG and FISHAC have access to the data as and when required in accordance with the Policy.

Explicit consent is sought from each member of FISG and FISHAC as to whether he/she wishes to receive information in relation to the activities of FISG and FISHAC and the manner in which such information is delivered.

Personal data relating to members of FISG and FISHAC is not held by third-parties.

BREACHES OF POLICY

Significant breaches of the Policy and related data protection procedures will be considered by the honorary officials of FISG and the board of Trustees/Directors and honorary officials of FISHAC.

REVIEW OF POLICY

The Policy is reviewed by the honorary officials of FISG and the board of Trustees/Directors and honorary officials of FISHAC on an annual basis.

APPROVAL

The Policy was first approved by the honorary officials of FISG and the board of Trustees/Directors and honorary officials of FISHAC on 20 March 2018.