Definitions 

1. Data protection principles  

The Charity is committed to processing data in accordance with its responsibilities under the GDPR.  Article 5 of the GDPR requires that personal data shall be: 

1. 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; 
2. adequate, relevant and limited to what is necessary in relation to the purposes for which they are  processed; 
3. 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; 
4. 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 
5. 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.”
6. General provisions  
7. This policy applies to all personal data processed by the Charity.  
8. The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this  policy.  
9. This policy shall be reviewed at least annually.  
10. The Charity shall register with the Information Commissioner’s Office as an organisation that  processes personal data.  
11. Lawful, fair and transparent processing  
12. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a  Register of Systems.  
13. The Register of Systems shall be reviewed at least annually.  
14. Individuals have the right to access their personal data and any such requests made to the charity  shall be dealt with in a timely manner.  
15. Lawful purposes  
16. All data processed by the charity must be done on one of the following lawful bases: consent,  contract, legal obligation, vital interests, public task or legitimate interests.  
17. The Charity shall note the appropriate lawful basis in the Register of Systems. c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent  shall be kept with the personal data.  
18. 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 Charity’s systems.  
19. Data minimisation  
20. The Charity shall ensure that personal data are adequate, relevant and limited to what is  necessary in relation to the purposes for which they are processed.  
21. No further considerations relevant to the Charity’s particular systems 
22. Accuracy  
23. The Charity shall take reasonable steps to ensure personal data is accurate.  
24. 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.  
25. No further Add considerations relevant to the Charity’s particular systems 
26. Archiving / removal  
27. To ensure that personal data is kept for no longer than necessary, the Charity shall put in place an  archiving policy for each area in which personal data is processed and review this process  annually.  
28. The archiving policy shall consider what data should/must be retained, for how long, and why.  
29. Security  
30. The Charity shall ensure that personal data is stored securely using modern software that is kept-

up-to-date.  

1. 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.  
2. 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.  
3. 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 Charity shall promptly assess the risk to  people’s rights and freedoms and if appropriate report this breach to the ICO. 

END OF POLICY