Context and overview

Key details:

• Policy prepared by: CMG/GM
• Approved by board / management on: 27/2/17
• Policy became operational on: 27/2/17
• Next review date: June 2018

Introduction

The Hub needs to gather and use certain information about individuals.
These can include Hub users, customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company's data protection standards - and to comply with the law.

Why this policy exists

This data protection policy ensures the Hub:

• Complies with data protection law and follows good practice
• Protects the rights of Hub useres, staff, customers and partners
• Is open about how it stores and processes individuals' data
• Protects itself from the risks of a data breach

Data protection law

The Data Protection Act 1998 and the GDPR, which is enforceable from 25th May 2018 and governs the collection, retention, use and transmission of information about living individuals and the rights those individuals have to see this information and describes how organisations - including the Hub - must collect, handle and store personal information.

As part of its obligations the Hub reviews this policy and considers its data protection registration on an annual basis. The Hub's registration number is ZA 227606 and further details of the Data Protection register entry can be found on the Information Commissioner's website at www.ico.org.uk/

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

1. Be processed fairly and lawfull
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant and not excessive
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Provessed in accordance with the rights of data subjects
7. Be protected in appropriate ways
8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

People, risks and responsibilities

Policy scope

This policy applies to:

• The Hub
• All staff and volunteers of the Hub
• All contractors, suppliers and other people working on behalf of the Hub

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• Any other information relating to individuals

Data protection risks

This policy helps to protect the Hub from some very real data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately.
• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with the Hub has some responsibility for ensuring data is collected, stored and handled appropriately and everyone that handles personal data must ensure that it is handled, transmitted and processed in line with this policy and the data protection principles.

However, these people have key areas of responsibility:

• The board of directors and Trustees is ultimately responsible for ensuring that the Hub meets its legal obligations and is responsible for:
  
  
  • Ensuring all Hub systems, services and Hub equipment used for storing data meet acceptable security standards.
  • Performing regular checks and scans to ensure security hardware and software is functioning properly.
  • Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.


• The data protection officer and Facilities Manager Guy Morris, is responsible for:
  
  
  • Keeping the board updated about data protection responsibilities, risks and issues.
  • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
  • Arranging data protection training and advice for the people covered by this policy.
  • Handling data protection questions from staff and anyone else covered by this policy.
  • Dealing with requests from individuals to see the data the Hub holds about them (also called "subject access requests").
  • Checking and approving any contracts or agreements with third parties that may handle the company's sensitive data.

General staff guidelines

• The only people able to access data covered by this policy should be those who need it for their work.
• Data should not be shared informally. When access to confidential information is required, employees can request it from the Facility Manager.
• The Hub will provide general training to all employees to help them understand their responsibilities when handling data.
• Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
• In particular, strong passwords must be used and they should never be shared unless required for the work being carried out.
• Personal data should not be disclosed to unauthorised people, either within the company or externally.
• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
• Employees should and must request help from the Facilities Manager or the data protection officer if they are unsure about any aspect of data protection.

Data storage

These rules describe how and where data should be safely stored.

When data is stored on paper, it should be kept in a secure, locked place where unauthorised people cannot see it.

These guidelines also apply todata that is usually stored electronicallybut has been printed out for some reason:

• When not required, the paper or files should be kept in a locked drawer or filing cabinet.
• Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
• Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

• Data should be protected by strong passwords that are changed regularly and never shared between employees.
• If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
• Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing service.
• Servers containing personal data should be sited in a secure location.
• Data should be backed up frequently. Those backups should be tested regularly, in line with the company's standard backup procedures.
• Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
• All servers and computers containing data should be protected by strong passwords approved security software and a firewall.

Data use

Personal data is of no value to the Hub unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
• Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
• Data must be encrypted before being transferred electronically.
• Personal data should never be transferred outside of the European Economic Area.
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data accuracy

The law requires the Hub to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort the Hub should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

• Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a Hub User's, a customer's details when they call.
• The Hub will make it easy for data subjects to update the information the Hub holds about them.
• Data should be updated as inaccuracies are discovered. For instance, if a Hub User or trustee or other individual or customer can no longer be reached on their stored telephone number, it should be removed from the database.

Subject access requests

All individuals who are the subject of personal data held by the Hub are entitled to:

• Ask what information the Hub holds about them and why.
• Ask how to gain access to it.
• Be informed how to keep it up to date.
• Be informed how the Hub is meeting its data protection obligations.

If a member of staff receives a request from an individual or an organisation to gain access to personal data held by the Hub about individuals DO NOT provide the data yourself.

If an individual wants to gain access to the data and is the subject of the data I.e Mary Jones wants to see her file, contacts the Hub requesting this information, this is called a subject access request. Please refer the request to the Facilities Manager who will process the subject access request.

Subject access requests from individuals should be made in writing.

Individuals will be charged £10 per subject access request. The Hub will aim to provide the relevant data within 14 days.

The Hub will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, the Hub will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board where necessary.

Providing information

The Hub aims to ensure that individuals are aware that their data is being processed, and that they understand that:

• How the data is being used
• How to exericise their rights

To these ends, the Hub has a privacy statement, setting out how data relating to individuals is used by the Hub.

This is available on request. A version of this statement is also available on the company's website.

We look forward to welcoming you!

Registered in England - Limited Company No. 3802499 -
Charity No.1078799