Charity1183140
STANLEYS COMMUNITY CENTRE
DATA PROTECTION AND GDPR POLICY
Introduction
This policy sets out the obligations of STANLEYS regarding data protection and the rights of
customers, business contacts, employees, trustees, volunteers, participants, supporters, donors
and any other data subjects engaged with the organisation in respect of their personal data, under
Data Protection Legislation such as the General Data Protection Regulation (GDPR) and the Data
Protection Act (DPA).
It also sets our obligations regarding the collection, processing, transfer, storage, and disposal of
personal data. The procedures and principles set out herein must be followed at all times by
STANLEYS its employees, trustees, volunteers, agents, contractors or any other parties working on
behalf of STANLEYS
As a Controller of personal data, STANLEYS recognises its duty to ensure that all such data is
handled properly and confidentially at all times, irrespective of whether it is held on paper or by
electronic means and covers the whole lifecycle of it.
Definitions
Data Owner – is the person or entity which can authorise or deny access to certain data and is
responsible for its accuracy and integrity.
Data Subject – the individual who is the subject of personal and sensitive information. NB; the
data protection act does not count as a data subject a deceased individual or an individual
who cannot be distinguished from others.
Personal Data – any information relating to an identified or identifiable natural person (‘data
subject’); an identifiable natural person is one who can be identified, directly or indirectly, in
particular by reference to an identifier such as a name, an identification number, location data,
an online identifier or to one or more factors specific to the physical, physiological, genetic,
mental, economic, cultural or social identity of that natural person.
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Data Controller – the natural or legal person, public authority, agency or other body which,
alone or jointly with others, determines the purposes and means of the processing of personal
data.
Data Processor – a natural or legal person, public authority, agency or other body which processes
personal data on behalf of the controller.
Personal Information – means information that identifies someone as an individual, such as:
1. personal details
2. family details
3. lifestyle and social circumstances
4. financial details
5. education and employment
6. visual images
Sensitive Personal Information – means information about:
1. physical or mental health details
2. racial or ethnic origin
3. religious or other beliefs of a similar nature
4. offences and alleged offences
5. criminal proceedings, outcomes and sentences
Data protection principles
The General Data Protection Regulation, regulates the data processing relating to living and
identifiable individuals. This includes the obtaining, holding, using or disclosing of such
information, and covers computerised records as well as manual filing systems. The principles
apply to “personal and sensitive personal data” from which the subjects of that data are
identifiable. Stanleys employees, volunteers, freelancers and trustees who process, use or have
access to any personal information in the course of their duties, will ensure that these principles
are followed at all times.
Stanleys data users must comply with the data protection principles of good practice which
underpin the Data Protection Act. To comply with the law, information must be collected and used
fairly, stored safely and not disclosed to any other person unlawfully.
Stanleys follows the Data Protection Principles outlined in General Data Protection Regulation,
which are summarised below:
1. Personal data will be processed fairly, lawfully and in a transparent manner;
2. Data will only be collected and used for specified, explicit and legitimate purposes;
3. Data will be adequate, relevant and not excessive;
4. Data will be accurate and up to date;
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5. Data will not be held any longer than necessary;
6. Data subject’s rights will be respected;
7. Data will be kept safe from unauthorised access, accidental loss or damage;
8. 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;
9. Data will not routinely be transferred to a country outside the European Economic Area,
unless that country has equivalent levels of protection for personal data.
Rights of data subjects
GDPR provides the following eight rights for individuals:
1. The Right to Be Informed
Stanleys Data Protection Officer can be contacted by:
1. emailing stanleyscommunitycentre@gmail.com or by post
2. Stanleys Community Centre 79-83 Stanley Road Morecambe Lancs LA31UT
The Data Protection Officer is the County Director who is responsible for overseeing the
implementation of this policy and for monitoring compliance with this policy and any other linked
policies & procedures.
Stanleys keeps secure records of all personal data collection, holding and processing, which
incorporates the following information:
1. The name and details of Stanleys its Data Protection Officer and any applicable third-party
data processors;
2. The purposes for which Stanleys collects, holds and processes personal data;
3. Details of the categories of personal data collected, held and processed by Stanleys and the
categories of data subject to which that personal data relates;
4. Details of any transfers of personal data to non-EEA countries including all mechanisms and
security safeguards;
5. Details of how long personal data will be retained by Stanleys
6. Detailed descriptions of all technical and organisational measures taken by Stanleys to
ensure the security of personal data.
Keeping Data Subjects Informed (Privacy Rights)
Stanleys has an overarching and organisational Consent & Privacy document that underpins all
departmental privacy notices. Privacy notices are the best way for us to tell individuals (e.g.
customers, staff, volunteers, trustees etc.) why and how we use personal and sensitive
information. The notices are used to share the specific detail on personal data processes that we
have in place across individual departments and teams.
Stanleys will:
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1. Where personal data is collected directly from data subjects, they will be informed of
its purpose at the time of collection;
2. Where personal data is obtained from a third party, the relevant data subjects will be
informed of its purpose normally at the time of sharing or as soon as reasonably possible
after the personal data is obtained.
The following information will be provided, usually in departmental privacy notices:
1. The purpose(s) for which the personal data is being collected and will be processed and
the legal basis justifying that collection and processing;
2. Where applicable, the legitimate interests upon which Stanleys is justifying its collection
and processing of the personal data;
3. Where the personal data is not obtained directly from the data subject, the categories
of personal data collected and processed;
4. Where the personal data is to be transferred to one or more third parties, details of
those parties;
5. Where the personal data is to be transferred to a third party that is located outside of
the European Economic Area (EEA), details of that transfer, including but not limited
to the safeguards in place;
6. Details of data retention;
7. Details of the data subject’s rights under Data Protection Legislation;
8. Where applicable, details of the data subject’s right to withdraw their consent to
Stanleys processing their personal data at any time;
9. Details of the data subject’s right to complain to the Information Commissioner’s Office,
the regulator;
10. Where applicable, details of any legal or contractual requirement or obligation
necessitating the collection and processing of the personal data;
11. Where applicable, details of any automated decision-making or profiling that will take
place using the personal data, including information on how decisions will be made,
the significance of those decisions and any consequences.
2. The Right of Access (Subject Access Requests)
Data subjects may make Subject Access Requests (SAR) at any time to find out more about
the personal data which Stanleys holds about them, what we are doing with that personal data
and why.
Anyone wishing to make a SAR must complete the Subject Access Request Form and send to
Stanleys Data Protection Officer by:
3. emailing stanleyscommunitycentre@gmail.com or
4. post, Stanleys Community Centre 79-83 Stanley Road Morecambe Lancs LA31UT
5. Responses to SARs shall normally be made within 30 calendar days of receipt, however
this may be extended by up to two months if the SAR is complex and/or numerous
requests are made. If additional time is required, the data subject will be notified.
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All SARs received shall be handled by the Data Protection Officer who will be supported by staff
from other departments when requested.
We do not charge a fee for the handling of normal SARs but we reserve the right to charge
reasonable fees for additional copies of information that have already been supplied to a data
subject, and/or for requests that are manifestly unfounded or excessive, particularly where such
requests are repetitive.
3. The Right to Rectification
Data subjects have the right to rectify any of their personal data that is inaccurate or
incomplete. We will rectify the personal data in question and inform the data subject of that
rectification, as quickly as possible, but within one month of the data subject informing Stanleys
of the issue. The period can be extended by up to two months in the case of complex requests.
If such additional time is required, the data subject shall be informed.
In the event that any affected personal data has been disclosed to third parties, those parties shall
be informed of any rectification that must be made to that personal data record and will be asked
to confirm the changes have been appropriately amended.
4. The Right to Erasure (‘the right to be forgotten’)
Data subjects have the right to request that Stanleys erases the personal data we hold about
them in the following circumstances:
1. It is no longer necessary for us to hold that personal data with respect to the purpose(s)
for which it was originally collected or processed;
2. The data subject wishes to withdraw their consent to Stanleys holding and processing
their personal data;
3. data subject objects to Stanleys holding and processing their personal data (and there is
no overriding legitimate interest to allow Stanleys to continue doing so)
4. The personal data has been processed unlawfully;
5. The personal data needs to be erased in order for Stanleys to comply with a particular
legal obligation;
6. The personal data is being held and processed for the purpose of providing
information services to a child.
Unless Stanleys has reasonable grounds to refuse to erase personal data, all requests for erasure
shall be complied with and the data subject informed of the erasure, within 30 calendar days of
receipt of the data subject’s request. The period can be extended by up to two months in the
case of complex requests. If such additional time is required, the data subject shall be informed.
In the event that any personal data that is to be erased in response to a data subject’s request
has been disclosed to third parties, those parties shall be informed of the need for erasure
(unless it is impossible or would require disproportionate effort to do so).
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5. The Right to Restrict Processing
Data subjects may request that we cease processing the personal data we hold about them. If a
data subject makes such a request, Stanleys will retain only the amount of personal data
concerning that data subject (if any) that is necessary to ensure that the personal data in
question is not processed further.
In the event that any affected personal data has been disclosed to third parties, those parties shall
be informed of the applicable restrictions on processing it (unless it is impossible or would
require disproportionate effort to do so).
6. The Right to Data Portability
Business processes should allow individuals to move, copy or transfer their personal data from one
environment to another in a safe and secure way, without any hindrance to the usability of the
data. The right to data portability only applies when each of the following are met:
1. The personal data an individual has provided to a controller;
2. Where the processing is based on the individual’s consent or the performance of a
contract;
3. When processing is carried out by automated means. (‘Processing by automated means’
is defined as personal data processed electronically, for example on a computer, smart
phone or call recording software).
7. The Right to Object
Data subjects have the right to object to Stanleys processing their personal data based on
legitimate interests, direct marketing (including profiling) and processing for scientific and/or
historical research and statistics purposes.
Where a data subject objects to Stanleys processing their personal data based on our
legitimate interests, we will cease such processing immediately, unless it can be demonstrated
that Stanleys legitimate grounds for such processing override the data subject’s interests, rights,
and freedoms or that the processing is necessary for the conduct of legal claims.
Where a data subject objects to Stanleys processing their personal data for direct marketing
purposes, Stanleys shall cease such processing immediately.
8. Rights with Respect to Automated Decision Making and Profiling
Stanleys does not usually use personal data in any automated decision-making processes.
Where such decisions have a legal (or similarly significant effect) on data subjects, those data
subjects have the right under the GDPR to challenge such decisions, requesting human
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intervention, expressing their own point of view, and obtaining an explanation of the decision
from Stanleys
The right described above does not apply in the following circumstances:
1. The decision is necessary for entry into, or the performance of, a contract between
Stanleys and the data subject;
2. The decision is authorised by law; or
3. The data subject has given their explicit consent.
Stanleys may use personal data for profiling purposes. When personal data is used for profiling
purposes, the following shall apply:
1. Clear information explaining the profiling shall be provided to data subjects, including
the significance and likely consequences of the profiling;
2. Appropriate mathematical or statistical procedures shall be used;
3. Technical and organisational measures shall be implemented to minimise the risk of errors.
If errors occur, such measures must enable them to be easily corrected; and
4. All personal data processed for profiling purposes shall be secured in order to prevent
discriminatory effects arising from profiling.
DATA SECURITY
Stanleys will ensure that the following measures are taken with respect to all communications
and other transfers involving personal data:
1. Personal data must never be included within the subject line or message body of an email;
2. All personal data documents legitimately transmitted via IT systems (e.g. email) must be
protected using a strong password and marked “confidential”
3. Personal data may be transmitted over secure networks only. Transmission over
unsecured networks is not permitted in any circumstances
4. Personal data contained in the body of an email, whether sent or received, should be
copied from the body of that email and stored securely. The email itself should be
deleted. All temporary files associated must also be deleted
1. Where personal data is to be transferred in hardcopy form it should be passed directly to
the recipient or sent using Special Delivery post and
2. All personal data to be transferred physically, whether in hardcopy form or on
removable electronic encrypted media shall be transferred in a suitable container
marked “confidential”.
Stanleys will ensure that the following measures are taken with respect to the storage of
personal data:
1. All electronic copies of personal data should be stored securely either by using passwords
or restricted permissions on folders.
2. All hardcopies of personal data, along with any electronic copies stored on physical,
removable media should be stored securely in a locked box, drawer, cabinet, or similar.
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3. All personal data stored electronically should be backed up daily with backups encrypted
and stored offsite.
4. No personal data should be stored on any mobile device (including, but not limited
to, laptops, tablets, and smartphones), whether such device belongs to Stanleys or
otherwise without approval of the appropriate member of the Senior Management
Team and, in the event of such approval, strictly in accordance with all instructions
and limitations described at the time the approval is given, and for no longer than is
absolutely necessary.
5. No personal data should be transferred to any personal device belonging to an employee,
and personal data may only be transferred to devices belonging to agents, contractors,
or other parties working on behalf of Stanleys where the party in question has agreed to
comply fully with this policy and all Data Protection Legislation (which may include
demonstrating to Stanleys that all suitable technical and organisational measures have
been taken).
When any personal data is to be erased or otherwise disposed of for any reason (including
where copies have been made and are no longer needed), it should be securely deleted and
disposed of.
Stanleys shall ensure that the following measures are taken with respect to the use of personal
data:
1. Personal data processed by Stanleys must only be used for the purpose it was collected for.
2. No personal data may be shared informally and/or transferred to an employee, trustees,
volunteers, agent, sub-contractor, or other party working on behalf of Stanleys If they
require access to any personal data that they do not already have access to, such access
should be formally requested from the relevant member of the Senior Management
Team.
3. Personal data must be handled with care at all times and should not be left unattended or
on view to unauthorised employees, trustees, volunteers, agents, sub-contractors, or
other parties at any time.
4. Where personal data held by Stanleys is used for marketing purposes, it shall be the
responsibility of the nominated person in each department to ensure that the
appropriate consent is obtained, documented for as long as deemed necessary and that
no data subjects have opted out.
Stanleys shall ensure that the following measures are taken with respect to IT and
information security:
1. All passwords used to protect personal data do not use words or phrases that can be
easily guessed or otherwise compromised. All passwords must contain a combination of
uppercase and lowercase letters, numbers, and symbols.
2. Under no circumstances should any passwords be written down or shared between
any employees, trustees, volunteers, agents, contractors, or other parties working on
behalf of Stanleys irrespective of seniority or department. If a password is forgotten, it
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must be reset using the applicable method. Operations staff do not have access to
passwords.
3. All software (including, but not limited to, applications and operating systems) will be
kept up-to-date. Operations staff shall be responsible for installing all security-related
updates as soon as reasonably and practically possible.
4. No software may be installed on any Stanleys -owned computer or device without the
prior approval of the Operations Staff.
Stanleys shall ensure that the following measures are taken with respect to the collection,
holding, and processing of personal data:
1. All employees, trustees, volunteers, agents, contractors, or other parties working on
behalf of Stanleys
1. shall be made fully aware of both their individual responsibilities and Stanleys
responsibilities under Data Protection Legislation and under this Policy and shall
be provided with a copy of this Policy;
2. Who only need access to, and use of, personal data in order to carry out their
assigned duties correctly shall have access to personal data held by Stanleys
3. will be appropriately trained to do so;
4. handling personal data will be appropriately supervised;
5. shall be required and encouraged to exercise care, caution, and discretion
when discussing work-related matters that relate to personal data, whether in the
workplace or otherwise.
2. Methods of collecting, holding, and processing personal data shall be regularly evaluated
and reviewed.
3. All personal data held by Stanleys shall be reviewed regularly.
4. Where other parties working on behalf of Stanleys handling personal data fails in their
obligations under this Policy that party shall indemnify and hold harmless Stanleys
against any costs, liability, damages, loss, claims or proceedings which may arise out of that
failure.
Stanleys may from time to time transfer (‘transfer’ includes making available remotely) personal
data to countries outside of the EEA.
The transfer of personal data to a country outside of the EEA shall take place only if one or more
of the following applies:
1. The transfer is to a country, territory, or one or more specific sectors in that country (or
an international organisation), that the European Commission has determined ensures
an adequate level of protection for personal data;
2. The transfer is to a country (or international organisation) which provides appropriate
safeguards in the form of a legally binding agreement between public authorities or
bodies; binding corporate rules; standard data protection clauses adopted by the
European Commission; compliance with an approved code of conduct approved by a
supervisory authority (e.g. the Information Commissioner’s Office); certification under an
approved certification mechanism (as provided for in the GDPR); contractual clauses
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agreed and authorised by the competent supervisory authority; or provisions inserted
into administrative arrangements between public authorities or bodies authorised by
the competent supervisory authority;
3. The transfer is made with the informed consent of the relevant data subject(s)
4. The transfer is necessary for the performance of a contract between the data subject
and Stanleys (or for pre-contractual steps taken at the request of the data subject);
5. The transfer is necessary for important public interest reasons;
6. The transfer is necessary for the conduct of legal claims;
7. The transfer is necessary to protect the vital interests of the data subject or other
individuals where the data subject is physically or legally unable to give their consent.
Data should be protected at all times, this includes practical approaches such as locking away
laptops when not in use and being careful who has access to where data is stored.
Any loss of personal data is a security breach and all breaches, near-misses and incidents must
be reported immediately to Stanleys by email to stanleyscommunitycentre@gmail.com
If a personal data breach occurs and that breach is likely to result in a risk to the rights and
freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination,
reputational damage, or other significant social or economic damage), the Data Protection
Officer must ensure that the Information Commissioner’s Office is informed of the breach
without delay, and in any event, within 72 hours after being made aware of it.
In the event that a personal data breach is likely to result in a high risk to the rights and freedoms
of data subjects, the Data Protection Officer will ensure that all affected data subjects are
informed of the breach directly and without undue delay.
Data breach notifications will include the following information:
1. The categories and approximate number of data subjects concerned;
2. The categories and approximate number of personal data records concerned;
3. The likely consequences of the breach;
4. Details of the measures taken, or proposed to be taken, by Stanleys to address the
breach including, where appropriate, measures to mitigate its possible adverse effects.
Training
It is the aim of Stanleys that all staff will be fully informed of their Data Protection obligations and
as a minimum we will provide annual training. An online tutorial is included in new starter
inductions and supervisors. Periodic refresher sessions are also undertaken from time to time
and additional training can be provided if a department requests it.
Responsibilities
Trustees
1.Overall responsibility for a policy which ensures compliance with the relevant statutes
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Heads Of/Managers
1. Implementation of procedures
2. Dissemination throughout their team
3. Ensuring day to day operational compliance
4. Reporting to the Executive Team
5. Reporting data incidents and near misses to the manager of Stanleys
Individual Responsibility
1. Compliance with procedures
2. Identifying potential improvements through day to day work
3. Reporting to the Heads Of/Managers
4. Reporting data incidents and near misses to the manager
Review and Evaluation of this Policy
This Policy will have a formal review date of two years however, if any aspect is found to be
inadequate, the Policy will be reviewed earlier.
DOCUMENT CONTROL SHEET
Document Name: Data Protection Policy
Document Owner: Robyn Thomas
Issue Date: April 2023
Review Date: March 2024
Document History: First issue April 2019
Document approved by: Trustees
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