Data protection policy

DATA PROTECTION POLICY of the Dementia Services Development Trust (the “Trust”)

Last Updated: 19.09.19

Definitions:

GDPR – the General Data Protection Regulation
Responsible Person – the board of directors of the Trust
Register of Systems – the register of all systems or contexts in which personal data is processed by the Trust

1. Data Protection Principles

• processed fairly, lawfully and in a transparent manner in relation to individuals;
• 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;
• adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• 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;
• 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 GDPR in order to safeguard the rights and freedoms of individuals; and
• 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

This policy applies to all personal data processed by the Trust. The Board shall take responsibility for the Trust’s ongoing compliance with this policy. The Board shall review this policy at least annually. The Trust shall, as soon as it is legally required to do so, register with the Information Commissioner’s office as an organisation that processes personal data.

3. Lawful, fair and transparent processing

To ensure its processing of data is lawful, fair and transparent, the Trust shall maintain a Register of Systems and shall review that Register at least annually. The current Register consists of the register of current donors and the central database of Trust contacts.

Individuals have the right to access their personal data and any such requests made to the Trust shall
be dealt with in a timely manner.

4. Lawful purposes

All data processed by the Trust must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests. The Trust’s current basis for all processing of personal data it carries out is that it requires to do so for the legitimate interests of the Trust. Where any other basis lies behind any processing of personal data carried out by the Trust, that basis shall be noted in the relevant Register of
Systems or in an amendment to this Policy.

Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data or in another appropriate place to which anyone in the Trust accessing the data shall have access. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Trust’s systems.

5. Data minimisation and accuracy

The Trust shall ensure that personal data are accurate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
The Trust shall ensure that steps are put in place to ensure that personal data is kept up to date where necessary for the lawful basis on which such data is processed.

6. Archiving / removal

To ensure that personal data is kept for no longer than necessary, the Trust shall put in place an archiving policy and review this policy annually. The archiving policy shall consider what data should or must be retained, for how long and why.

7. Security

The Trust shall ensure that personal data are stored securely using appropriate software that is kept up to date. Access to personal data shall be limited to personnel who need access and appropriate security shall be put in place  to avoid unauthorised sharing of information.

When personal data is deleted, this should be done safely, such that the data are irrecoverable.

Appropriate back-up and disaster recovery solutions shall be put in place.

8. 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 Trust shall promptly assess the risk to people’s rights and freedoms and, if appropriate, report this breach to the ICO.