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Data protection policy
Context and overview
Policy prepared by: Zena Gardner
Approved by trustees on: 21st May 2018
Policy became operational on: 24th May 2018
Next review date: 24th May 2019
The Animal Team needs to gather and use certain information about individuals in order to be able to offer our services to animals in need.
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 The Animal Team:
Complies with data protection law and follow good practice
Protects the rights of volunteers, clients and 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 Animal Team — 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 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:
1. Be processed fairly and lawfully
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant and not excessive
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Processed in accordance with the rights of data subjects
7. Be protected in appropriate ways
8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
Volunteers – Individuals that offer to help us help service users by way of, including but not limited to Homechecking, Transporting, Assessing.
Staff – Volunteer staff including directors, trustees and group admin.
Service Users – Animal Welfare Individuals / charities, including but not limited to rescues and pound pullers.
People, risks and responsibilities
This policy applies to:
The head office of The Animal Team
All branches of The Animal Team
All staff and volunteers of The Animal Team
All contractors, suppliers and other people working on behalf of The Animal Team
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998.
This can include:
Names of individuals
…plus any other information relating to individuals
Data protection risks
This policy helps to protect The Animal Team 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.
Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for, volunteers with or uses the The Animal Team has some responsibility for ensuring data is 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 The Animal Team meets its legal obligations.
The data protection officer is responsible for:
Keeping the board 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 The Animal Team holds about them (also called ‘subject access requests’).
Checking and approving any contracts or agreements with third parties that may handle the charity’s sensitive data.
The Board of Trustees are 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.
General staff / Volunteer guidelines
The only people able to access data covered by this policy should be those who need it to successfully complete our services.
Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
Employees, volunteers and any one using our service (such as rescues) who would need personal information to assist us with the service provision to them 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 company or externally.
ANY DATA REQUESTS relating to personal information gained via The Animal Team in any way should be redirected to Zee Gardner to deal with directly with whoever is requesting personal data.
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 and/or volunteers should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
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 CD or DVD), 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 company’s standard backup procedures.
Data saved to personal laptops and mobile devices should be protected by a device lock password and should not be saved onto these devices, but access via encrypted means – such as gmail app, messenger app, whatsapp and googledrive.
All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to The Animal Team unless the business can make use of it. Therefore we only keep personal details for the length of time that is necessary for us to provide our services.
Personal data provided to The Animal Team will be processed under the following circumstances / conditions;
The Animal Team will only keep personal information of volunteers for as long as they can assist us to provide our services to service users.
When someone chooses to cease volunteering for The Animal Team, we will ask permission to keep their details on file (usually in the cases of people who are only ending their volunteering help to us on a temporary basis as this will mean we do not have to take all the information again when you are able to help and we can just confirm the details we hold are correct.) If permission to retain personal information is not given we will completely delete any personal information we hold.
The Animal Team will share volunteers personal data where it is necessary to provide our service to service users. For example, we may pass your necessary personal information onto a service user so that they are able to advise an adoption applicant of whom will be attending to perform a homecheck.
Personal data of third parties – such as adoption applicants – will be processed and stored in compliance with this policy.
All volunteers and staff will be required to permanently delete any data as soon as it is no longer needed.
The Animal Team will share service users personal data with volunteers who have agreed to assist us provide our service to you.
Personal data of service users will be processed and stored in compliance with this policy.
Transporters may have to receive and share data of pick up and drop off points and change over volunteers. Once a transport run is complete all volunteers are required to permanently destroy any data.
How our staff / volunteers / service should process data;
When working with personal data, employees / volunteers / service users should ensure the screens of their computers are always locked when left unattended.
Personal data should not be shared informally by anyone.
Data must be encrypted before being transferred electronically.
Personal data should never be transferred outside of the European Economic Area.
Employees / Volunteers / Service Users should not save copies of personal data to their own personal computers. Always access and update the central copy of any data.
Employees / Volunteers / Service Users should be able to provide information on how a data subjects personal data has been shared in accordance with this policy.
The law requires The Animal Team 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 Animal Team should put into ensuring its accuracy.
It is the responsibility of all employees 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 / volunteers / service users should not create any unnecessary additional data sets.
Staff / volunteers / service users should take every opportunity to ensure data is updated.
The Animal Team will make it easy for data subjects to update the information The Animal Team holds about them. For instance, you can email us at any time to request the information we hold on you so you are able to confirm any amendments.
Data should be updated as inaccuracies are discovered. For instance, if a data subject cannot be contacted on the stored mobile or email address then this information shall be assumed incorrect and deleted.
Subject access requests
All individuals who are the subject of personal data held by The Animal Team are entitled to:
Ask what information the company 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 company is meeting its data protection obligations.
If an individual contacts the company 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 firstname.lastname@example.org.
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 Animal Team will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
We will only ever exercise our right to disclose data outside of this policy when requested to do so by law or if an animal welfare issue is identified.
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