The Administration Team is committed to being transparent about how it collects and uses the personal data and to meeting its data protection obligations. This policy sets out our commitment to data protection, and individual rights and obligations in relation to personal data.
“Personal data” is any information that relates to an individual who can be identified from that information. Processing is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.
“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.
Data Protection Principles
The Administration Team processes personal data in accordance with the following data protection principles:
- We process personal data lawfully, fairly and in a transparent manner.
- We collect personal data only for specified, explicit and legitimate purposes.
- We process personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
- We keep accurate personal data and take all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
- We keep personal data only for the period necessary for processing.
- We adopt appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.
The Administration Team explains to individuals the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data of individuals for other reasons.
The Administration Team keeps a record of its processing activities in respect of personal data in accordance with the requirements of the General Data Protection Regulation (GDPR).
Individuals have a number of rights in relation to their personal data.
Subject Access Requests
Individuals have the right to make a subject access request. If an individual makes a subject access request, The Administration Team will tell the individual: –
- whether or not their data is processed and if so why, the categories of personal data concerned and the source of the data if it is not collected from the individual;
- to whom their data is or may be disclosed,
- for how long their personal data is stored (or how that period is decided);
- their rights to rectification or erasure of data, or to restrict or object to processing;
- their right to complain to the Information Commissioner if they think The Administration Team has failed to comply with their data protection rights; and
The Administration Team will also provide the individual with a copy of the personal data undergoing processing. This will normally be in electronic form if the individual has made a request electronically.
To make a subject access request, the individual should send the request to email@example.com In some cases, we may need to ask for proof of identification before the request can be processed. The Administration Team will inform the individual if it needs to verify their identity and the documents it requires.
The Administration Team will normally respond to a request within a period of one month from the date it is received.
If a subject access request is manifestly unfounded or excessive, we are not obliged to comply with it. Alternatively, we may respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which we have already responded. If an individual submits a request that is unfounded or excessive, we will notify you that this is the case and whether or not it will responded to.
Individuals have a number of other rights in relation to their personal data. They can require The Administration Team to:
- rectify inaccurate data;
- stop processing or erase data that is no longer necessary for the purposes of processing;
- stop processing or erase data if the individual’s interests override The Administration Team’s legitimate grounds for processing data (where we rely on its legitimate interests as a reason for processing data);
- stop processing or erase data if processing is unlawful; and
- stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual’s interests override The Administration Team’s legitimate grounds for processing data.
To ask us to take any of these steps, the individual should send the request to firstname.lastname@example.org
The Administration Team takes the security of personal data seriously. We have internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties.
We employ third party data specialists who utilise a secure environment to allow users to refer manage and update client data in a secure and compliant manner.
Personal data is collected about you from information entered on our forms, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally-identifying information like Internet Protocol (IP) addresses.
When you give us personal information, we take steps to make sure that it’s treated securely. Any sensitive information is encrypted and protected with the following software – 128 Bit encryption on SSL. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.
Where we engage third parties to process personal data on our behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical measures to ensure the security of data.
All third parties we work with will undergo a due diligence and vetting process before we enter into contractual arrangements with them.
If we discover that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, we will report it to the Information Commissioner within 72 hours of discovery. The Administration Team will record all data breaches regardless of their effect.
If the breach is likely to result in a high risk to the rights and freedoms of individuals, we will tell the affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures we has taken.
International Data Transfers
The Administration Team does not transfer personal data to countries outside the EEA.
Individual & Third-Party Responsibilities
Individuals and third parties are responsible for helping The Administration Team keep personal data up to date. Individuals and third parties should let us know if data provided to us changes, for example if an individual changes their address or their contact details.