Purpose

New Life Church (Suffolk) and all its projects take privacy seriously and are committed to working in accordance with the General Data Protection Regulations (GDPR).

Persons affected

All staff, team leaders, volunteers and users of activities organised by New Life Church, (Suffolk).

Policy

The charity is committed to processing data in accordance with its responsibilities under the GDPR. Article 5 of the GDPR requires that personal data shall be:

  1. Processed lawfully, fairly and in a transparent manner in relation to individuals;
  2. 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 purpose or statistical purposes shall not be considered to be incompatible with the initial purposes;
  3. Adequate, relevant and limited to what is necessary in relation to the purpose for which they are processed;
  4. Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  5. 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 in so far 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 GDPR in order to safeguard the rights and freedoms of individuals; and
  6. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing against accidental loss, destruction or damage using appropriate technical or organisational measures.

Policy

This policy applies to all personal data processed by the Charity. To ensure the charity maintains compliance with this policy New Life Church (Suffolk) has designated Caroline Davies to be the responsible person within the charity who will monitor the data processing procedures & ensure data protection. As part of the ongoing commitment to data protection and working with the GDPR guidelines the charity will register with the Information Commissioner’s office as an organisation that processes personal data.

Lawful, fair and transparent processing

To ensure its processing of data is lawful, fair and transparent, the Charity 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 the Charity shall be dealt with promptly.

Lawful purposes

All data processed by the Charity must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests. Where consent is relied upon as a lawful basis for processing data we will keep evidence of opt-in consent. Where communications are sent to individuals based on their consent, the option for individuals to withdraw consent is clearly explained and available with systems in place to ensure withdrawal is processed correctly.

Data minimisation

The Charity shall ensure that any personal data collected is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. When collecting personal data from an individual the reason for obtaining the information will always be made clear and transparent.

Accuracy

The Charity shall take reasonable steps to ensure personal data is accurate and steps shall be put in place to ensure that personal data is kept up to date.

Archiving/removal

To ensure that personal data is kept no longer than necessary, the Charity shall put in place archiving procedures for each area of the Charity in which personal data is processed and review this annually. The archiving procedures shall consider what data should/must be retained, for how long and why.

Security

The Charity shall ensure that:

  • personal data stored digitally is kept securely using modern software that is kept up to date. Each computer is password protected and protection systems are in place;
  • all paper copies of personal data are stored in a locked cupboard within a secure office.
  • access to personal data shall be limited to personnel who need access and appropriate security is in place to avoid unauthorised sharing of information in conjunction with our confidentiality policy.
  • when personal data is deleted it is done safely so none of the data is recoverable, any paper copies are shredded and destroyed.

Breach

In the event of a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Charity shall promptly assess the risk to people’s rights and freedoms and, if appropriate, report this breach to the ICO.

Monitoring

As part of the ongoing compliance with GDPR, we will regularly review our data processing procedures and ensure our Data Protection Policy is being followed. Any data protection issues or breaches will be dealt with promptly and will be reported to the leadership team and trustees, and amendments will be implemented.