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Data Protection Policy
Shepreth Wildlife Conservation Charity needs to gather and use certain information about individuals. These can include volunteers, employees, members of the public 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 Shepreth Wildlife Conservation Charity complies with data protection law and follows good practice, protects the rights of staff, customers and partners, is open about how it stores and processes individuals’ data and protects itself from the risks of a data breach.
Data Protection Law
The Data Protection Act 1998 describes how organisations, including
Shepreth Wildlife Conservation Charity, must collect, handle and store personal information. These rules apply regardless of whether data are 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
This policy applies to:
The management
All staff and volunteers of Shepreth Wildlife Conservation Charity
All contractors, suppliers and other people working on behalf of Shepreth Wildlife Conservation Charity
It applies to all data the charity 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
… plus any other information relation to the individual.
Data Protection Risks
This policy helps to protect Shepreth Wildlife Conservation Charity 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 charity uses data relating to them.
Reputational damage. For instance, the charity could suffer if hackers successfully gained access to sensitive data.
Responsibilities
Everyone who works for or with Shepreth Wildlife Conservation Charity has some responsibility for ensuring data are 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 board of trustees is ultimately responsible for ensuring that Shepreth Wildlife Conservation Charity meets its legal obligations.
The Data Protection Officer, SWCC Board of Trustees, is responsible for:
Keeping the SWCC team 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 Shepreth Wildlife Conservation Charity holds about them (also called ‘subject access requests’).
Addressing any data protection queries from journalists or media outlets like newspapers.
Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
The IT Manager, SWCC Board of Trustees, is responsible for:
Ensuring all systems, services and 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.
Approving any data protection statements attached to communications such as emails and letters.
Checking and approving any contracts or agreements with third parties that may handle the charity’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.
Shepreth Wildlife Conservation Charity will provide 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.
Personal data should not be disclosed to unauthorised people, either within the charity 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 request help 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 are stored on paper, it should be kept in a secure place where unauthorised people cannot see it. These guidelines also apply to data 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 / office.
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 are 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 are stored on removable media (like a USB data storer), 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 services.
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.
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 approved security software and a firewall.
Data Accuracy
The law requires Shepreth Wildlife Conservation Charity to take reasonable steps to ensure data are kept accurate and up to date.
It is the responsibility of all staff 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.
Data should be updated as inaccuracies are discovered.
Subject Access Requests
All individuals who are the subject of personal data held by Shepreth Wildlife Conservation Charity are entitled to:
Ask what information the charity 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 charity is meeting its data protection obligations.
If an individual contacts the charity requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the data controller at swcc@sheprethwildlifepark.co.uk. The data controller can supply a standard request form, although individuals do not have to use this.
Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 days.
The data controller 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, Shepreth Wildlife Conservation Charity will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance where necessary.
Providing Information
Shepreth Wildlife Conservation Charity aims to ensure that individuals are aware that their data are being processed, and that they understand:
How the data are being used
How to exercise their rights