Last updated October 2020
GDPR - means the General Data Protection Regulation.
Responsible Person - means Hifsa Haroon-Iqbal (Chairperson of SWR)
Register of Systems - means a register of all systems or contexts in which personal data is processed by SWR.
1. Data protection principles
SWR is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
processed lawfully, fairly 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 SWR.
The Responsible Person shall take responsibility for SWR’s ongoing compliance with this policy.
This policy shall be reviewed at least every 2 years.
As a not-for-profit organisation who only handles data for purposes of helping our group of people, SWR is exempt from needing to register with the ICO. The ICO website states we don’t have to have a data protection officer, unless we want to, as our level of use of personal data is low.
3. Lawful, fair and transparent processing
To ensure its processing of data is lawful, fair and transparent, SWR shall maintain a Register of Systems.
The Register of Systems shall be reviewed at least annually.
Individuals have the right to access their personal data and any such requests made to SWR shall be dealt with in a timely manner.
4. Lawful purposes
All data processed by SWR must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
SWR shall note the appropriate lawful basis in the Register of Systems.
Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
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 SWR’s systems.
5. Data minimisation
SWR shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
SWR shall take reasonable steps to ensure personal data is accurate.
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.
7. Archiving / removal
To ensure that personal data is kept for no longer than necessary, SWR shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
The archiving policy shall consider what data should/must be retained, for how long, and why.
SWR shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
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.
When personal data is deleted this should be done safely such that the data is irrecoverable.
Appropriate back-up and disaster recovery solutions shall be in place.
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, SWR shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
SWR Register of Systems
A SWR circulation list with the email addresses of all members, volunteers and supporters of SWR will be held by SWR secretary. The leader of each functioning action group shall hold the email addresses of members of their group. These individuals will store this personal data on a password protected computer, and only use it for the purpose of legitimate interest. Emails sent to the SWR circulation list will use bcc function for privacy of individual email addresses.
Personal information for families supported by SWR (names, addresses, email addresses, telephone numbers) will only be gathered with their verbal consent and then held by the SWR secretary, the Befriender coordinators and specific family befrienders for the purpose of legitimate interest.
New supporters, members or volunteers will be asked to provide their email address to SWR. The secretary will then add them to the SWR circulation list, and forward the email address to the leader of each functioning group in which they wish to volunteer.
Minutes taken of SWR meetings in paper form often contain personal details, and will be shredded once typed up. No paper copies of previous minutes will be handed out at meetings. All emailed minutes will have a statement asking recipients not to print the minutes in order to maintain confidentiality. Within all minutes refugee family members will be referred to by their initials.
An offer of removal from the SWR circulation list will be offered annually to ensure ongoing consent.
Members, supporters and volunteers of SWR will not share/copy/ forward SWR emails in order to avoid confidential information being sent on an email thread.