Data Protection Policy
Introduction
These can include coaches, volunteers, players, parents, carers, spectators, 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 BWFC:
Complies with data protection law and follow good practice.
Protects the rights of staff, customers and partners.
Is open about how it stores and processes individual s’ data.
Protects itself from the risks of a data breach.
Data protection law
The Data Protection Act 1 998 describes h ow organisations – including BWFC- must collect
handle and store personal information.
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:
Be processed fairly and lawfully.
Be obtained only for specific, lawful purposes.
Be adequate, relevant and not excessive.
Be accurate and kept up to date.
Not be held for any longer than necessary.
Processed in accordance with the rights of data subjects.
Be protected in appropriate ways.
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
The policy applies to:
BWFC
All staff and volunteers of BWFC 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
• Telephone numbers
• …plus, any other information relating to individuals.
Data protection risks
This policy helps to protect TGFC 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 volunteers for BWFC has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that it is handled and
processed in line with this policy and data protection principles. However, these people have key areas of responsibility:
• The Directors are ultimately responsible for ensuring that BWFC meets its legal obligations.
• The Committee, are responsible for:
o Keeping volunteers updated about data protection responsibilities, risks and issues.
o Reviewing all data protection procedures and related policies, in line with an agreed schedule.
o Arranging data protection advice for the people covered by this policy.
o Handling data protection questions from volunteers and anyone else covered by this policy.
o Dealing with requests from individuals to see
the data BWFC holds about them (also called ‘subject access requests’).
o Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
o Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
o Performing regular checks and scans to ensure security hardware and software is functioning properly.
o Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
o Approving any data protection statements attached to communications such as emails and letters.
o Addressing any data protection queries from journalists or media outlets like newspapers.
o Where necessary, working with other volunteers to ensure any initiatives abide by data protection principles.
General Volunteer 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, volunteers can request it from the Committee.
• Volunteers should keep all data secure, by taking sensible precautions and following the guidelines be low.
• Personal data should not be disclosed to unauthorised people.
• 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.
• Volunteers should request help from the Committee or the 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 place where unauthorised people cannot see it.
These guideline s also apply to data that is usually stored electronically but has been
printed out for some reason:
• When not required, the paper or files should be kept in a locked drawer or filing cabinet.
• Volunteer s should make sure paper and printouts are not left where unauthorised people could see them.
• 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, away from general office space.
• 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 p hone s. All servers and computers containing data should be protected by approved security software and a firewall.
Data Use
Personal data is of no value to BWFC unless the organisation 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, volunteers 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 BWFC 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
BWFC 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.
Volunteers should take every opportunity to ensure data is updated.
Data should be updated as inaccuracies are discovered.
Subject access requests
All individuals who are the subject of personal data held by BWFC are entitled to:
Ask what information the organisation 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 company is meeting its data protection obligations.
If an individual contacts the organisation requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the Committee Member.
BWFC will aim to provide the relevant data within 14 days. BWFC 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, BWFC will disclose requested data. However, BWFC will ensure the request is legitimate, seeking assistance from the local FA.
Providing information
BWFC aims to ensure that individuals are aware that their data is being processed, and
that they understand:
How the data is being used
How to exercise their rights
To these ends, the company has a privacy statement, setting out how data relating to
individuals is used by the company.
END OF POLICY
