The 19 Project uses personal data about living individuals for the purpose of general administration and communication. These can include names, personal contact numbers and addresses.
This policy describes how this personal data is collected, handled and stored to meet our data protection standards - and to comply with the law. This is inline with the EU General Data Protection Regulations (GDPR).
Why this policy exists
This data protection policy ensures The 19 Project:
- Complies with data protection law and follows good practice.
- Protects the rights of staff, the congregation and any associated partners.
- Is open about how it stores and processes individuals’ data.
- Protects itself from the risks of a data breach.
Data Protection Law
The Data Protection Act 1998 describes how organisations - including The 19 Project - 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 carefully collected, safely stored stored 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 specified, 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.
Data Protection Risks
This policy helps to protect The 19 Project 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.
- Reputation damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with The 19 Project has responsibility for ensuring data is collected, stored and handled appropriately and processed in line with this policy and data protection principles.
The Data Controller 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.
- 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.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Data Controller.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
These guidelines 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.
- 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 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 USB or CD), 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, in line with the Project's standard backup procedures.
- 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.
Personal data is of no value to The 19 Project 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, The 19 Project 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.
The law requires The 19 Project 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 The 19 Project should put into ensuring its accuracy.
Subject Access Requests
All individuals who are subject of personal data held by The 19 Project are entitled to:
- Ask what information is held about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed how The 19 Project is meeting its data protection obligations.
If an individual contacts the organisation requesting this information, this is called a subject access request.
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, The 19 Project will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the organisation’s legal advisers where necessary.
The 19 Project 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