Data Protection policy for the Sale Photographic Society – 2017
Aims of this Policy
Sale Photography Society (hereafter called SPS) needs to keep certain information regarding its general and committee members to carry out its day to day operations, to meet its objectives and to comply with legal obligations.
The organisation is committed to ensuring any personal data will be dealt with in line with the Data Protection Act (DPA) 1998. To comply with the law, personal information will be collected and used fairly, stored safely and not disclosed to any other person unlawfully.
The aim of this policy is to ensure that everyone handling personal data is fully aware of the requirements and legislation in accordance with the data protection procedures. This document also highlights key data protection procedures within the organisation.
This policy covers all committee members and the general membership who need access to any formal databases.
In line with the Data Protection Act 1998 principles, SPS will ensure that personal data will: Be obtained fairly and lawfully and shall not be processed unless certain conditions are met
- Be obtained for a specific and lawful purpose
- Be adequate, relevant but not excessive
- Be accurate and kept up to date
- Not be held longer than necessary
- Be processed in accordance with the rights of data subjects
- Be subject to appropriate security measures
- Not to be transferred outside the European Economic Area (EEA)
The definition of ‘Processing’ is obtaining, using, holding, amending, disclosing, destroying and deleting personal data. This includes some paper based personal data as well as that kept on computers or used by any remote application.
The Personal Data Guardianship Code suggests five key principles of good data governance on which best practice is based. The organisation will seek to abide by this code in relation to all the personal data it processes, i.e.
- Accountability: those handling personal data follow publicised data principles to help gain public trust and safeguard personal data.
- Visibility: Data subjects should have access to the information about themselves that an organisation holds. This includes the right to have incorrect personal data corrected and to know who has had access to this data.
- Consent: The collection and use of personal data must be fair and lawful and in accordance with the DPA’s eight data protection principles. Personal data should only be used for the purposes agreed by the data subject. If personal data is to be shared with a third party or used for another purpose, the data subject’s consent should be explicitly obtained.
- Access: Everyone should have the right to know the roles and groups of people within an organisation who have access to their personal data and who has used this data.
- Stewardship: Those collecting personal data have a duty of care to protect this data throughout the data life span.
Type of information processed
SPS processes the following personal information:
- Members contact details (address/phone numbers) and email addresses. This is intended to be used for email circulation by the group of officers as defined below.
Personal information is kept in the following forms:
- Computer based systems including Microsoft Word and Excel or similar applications; databases and electronic address books.
Groups of officers within the organisation who will process personal information are:
- The SPS secretary (who will hold the master copy)
- The SPS competition secretaries
Under the Data Protection Guardianship Code, overall responsibility for personal data in a not for profit organisation rests with the governing body. In the case of Sale Photographic Society, this is the committee members.
The governing body delegates tasks to the ‘Data Controller’ who will be nominated by the committee. The Data Controller is responsible for:
- understanding and communicating obligations under the Act
- identifying potential problem areas or risks
- producing clear and effective procedures
The Sale Photographic Society secretary and main competitions secretary who process personal information must ensure they not only understand but also act in line with this policy and the data protection principles.
Breach of this policy will result in suspension of the member and they will be brought before the next committee meeting to account for their actions
To meet our responsibilities the committee members will:
- Ensure any personal data is collected in a fair and lawful way;
- Explain why it is needed at the start;
- Ensure that only the minimum amount of information needed is collected and used;
- Ensure the information used is up to date and accurate;
- Review the length of time information is held;
- Ensure it is kept safely;
- Ensure the rights people have in relation to their personal data can be exercised
We will ensure that:
- Everyone managing and handling personal information is trained to do so;
- Anyone wanting to make enquiries about handling personal information, whether a general or committee member, knows what to do;
- Any disclosure of personal data will be in line with our procedures;
- Queries about handling personal information will be dealt with swiftly and politely.
Training and awareness raising about the Data Protection Act and how it is followed in this organisation will take the following forms:
On appointment to the committee, a copy of this document will be shared with the member together with a verbal overview of the Data Protection Act
Gathering and checking information
Before personal information is collected, we will consider:
- The minimum amount of information required to keep the membership aware of SPS and other photography related events.
- All members and ex-members who expressed a wish to receive emails will be asked to update their request every year and deleted from the SPS records if no confirmation is received.
We will inform people whose information is gathered about the following
- It will be included on the standard form that ‘All data storage will be in accordance with the Data Protection Act (DPA) 1998’.
We will take the following measures to ensure that personal information kept is accurate
- This will be checked by the appointed Data Controller
Personal sensitive information will not be used apart from the exact purpose for which permission was given.
SPS will take steps to ensure that personal data is kept secure at all times against unauthorised or unlawful loss or disclosure. The following measures will be taken:
- All committee members are accountable for compliance of this policy. A committee member could be held personally liable for any penalty arising from a breach that they have made.
- Any unauthorised disclosure made by a general SPS member may result in the termination of their membership.
Subject Access Requests
Anyone whose personal information we process has the right to know:
- What information we hold and process on them
- How to gain access to this information
- How to keep it up to date
- What we are doing to comply with the Act.
They also have the right to prevent processing of their personal data in some circumstances and the right to correct, rectify, block or erase information regarded as wrong.
Individuals have a right under the Act to access certain personal data being kept about them on computer and certain files. Any person wishing to exercise this right should apply in writing to the appointed Data Controller
Queries about handling personal information will be dealt with swiftly and politely.
We will aim to comply with requests for access to personal information as soon as possible, but will ensure it is provided within the 40 days required by the Act from receiving the written request.
This policy will be reviewed at intervals of two years to ensure it remains up to date and compliant with the law.
I confirm I have read and understood SPS’s Data Protection Policy and will act in accordance with it and I have initialled each page.
I am connected with this organisation in my capacity as a
- Member who requires access to SPS contact details
- Committee member
Please return this form to the appointed Data Controller