Data Protection Policy
Bridestowe Village Hall’s Data Protection Policy
The Trustees of Bridestowe Village Hall (BVH) are committed to processing data in accordance with its responsibilities under the GDPR. To achieve this we commit to the following principals when handling your personal data and we will ensure that it is
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; with every reasonable step taken to ensure that personal data that is 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 is 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; 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.”
g. The Trustees assure all users that personal data collected will never be sold or made available to 3rd parties without your specific consent
2. General provisions
a. This policy applies to all personal data processed by BVH.
b. The Trustees take responsibility for the BVH’s ongoing compliance with this policy.
c. This policy shall be reviewed annually at the AGM .
d. BVH is not required to register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
a. To ensure its processing of data is lawful, fair and transparent, the Trustees commit to maintaining appropriate systems that are compliant with the relevant GDPR.
b. These systems shall be reviewed annually at the AGM to ensure their fitness for purpose.
c. Individuals have the right to access their personal data and may request we delete any such data. The Trustees will ensure requests of this nature shall be dealt with in a timely manner.
4. Lawful purposes
a. All data processed by BVH is done so on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
b. BVH’s lawful basis is primarily contractual ie User Hire and individual service provision.
5. Data minimisation
a. The Trustees will ensure that personal data gathered and retained is limited to that which is deemed adequate and relevant to what is necessary in relation to the purposes for which they are processed.
6. Accuracy
a. The Trustees will take appropriate steps to ensure personal data we hold is accurate.
b. Where necessary for the lawful basis on which data is processed, we will endeavour to ensure that personal data is kept up to date.
7. Archiving / removal
a. The Trustees shall ensure that personal data is kept for no longer than necessary and will normally be deleted after 3 years unless we have further reason to use the information ie repeat bookings
b. All information retained will only be accessible to the Trustees
8. Security
a. All personal data stored will be done so securely using modern secure software that is kept-up-to-date.
b. Access to personal data shall be limited only to the Trustees who need access and appropriate care will be taken to avoid unauthorised sharing of information.
c. When personal data is deleted this will be done safely so that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions are 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 BVH Trustees shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
23/5/2018