1. Data protection principles

We are committed to processing data in accordance with its responsibilities under the DPA*.
DPA requires that personal data shall be:

• a. processed lawfully, fairly and in a transparent manner in relation to individuals;
• b. 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;
• c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• d. 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;
• e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for 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 DPA in order to safeguard the rights and freedoms of individuals; and
• f. processed in 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.

2. General provisions

• a. This policy applies to all personal data processed.
• b. Responsibility shall be taken for the ongoing compliance with this policy.
• c. This policy is reviewed at least annually.

3. Lawful, fair and transparent processing

• a. To ensure its processing of data is lawful, fair and transparent, a Register is maintained.
• b. The Register is reviewed at least annually.
• c. Individuals have the right to access their personal data and any such requests made shall be dealt with.

4. Lawful purposes

• a. All data-processing relies on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
• b. The appropriate lawful basis is noted in our Register.
• c. Submitting personal data serves as a consent for processing and storing data until permission is revoked.
• d. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available.

5. Data minimisation

It shall be ensured that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

6. Accuracy

• a. Reasonable steps shall be taken to ensure personal data is accurate.
• b. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. Archiving / removal

• a. To ensure that personal data is kept for no longer than necessary, a policy shall be put in place and reviewed annually.
• b. This policy shall consider what data should/must be retained, for how long, and why.

8. Security

• a. It shall be ensured that personal data is stored in a secure and modern way.
• b. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
• c. When personal data is deleted this should be done safely such that the data is irrecoverable.
• d. Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss,
alteration, unauthorised disclosure of, or access to, personal data, the risk to people’s rights
and freedoms shall be assessed promptly and if appropriate this breach shall be reported to
authorities.

* DPA refers to Data Protection Act 2018 which implements the EU’s General Data Protection Regulation.

For providing useful information to create our data protection policy we are grateful for https://whitefuse.com/blog/privacy-policy-notice- template