Security, Privacy & Data Protection
We take the privacy of your personnal information seriously.
We will ensure your personnal data is stored securely and will not sell or give it to third parties or permit unauthorised access.
How your information is used
The information you provide here will be used in connection with the specified activities, including keeping you informed of events, and for internal record keeping purposes.
Resources & links
Data Protection Policy
The Grain House Trust (GHT) need to collect and use certain types of information about the Data Subjects who come into contact with it in order to carry on its work. The GHT complies with the principles of the Data Protection Act 1998 and aims to maintain consistently high levels of best practice in its processing of personal data.
This policy applies to all staff employed by the GHT, those sub-contracted by the GHT, volunteers and any casual workers.
The GHT is registered with the Information Commission’s Office as follows: Grain House Trust – Z6822032
The GHT may share personal data with other organisations. The GHT may pass personal data to third parties if prior consent has been obtained by the Data Subject.
The GHT will use standard, approved statements about data protection in all of the GHT’s literature and on its websites in which personal data is collected.
The GHT regards the lawful and correct treatment of personal information as very important and intends to ensure that personal information is treated lawfully and correctly.
To this end the GHT will adhere to the Principles of Data Protection, as detailed in the Data Protection Act 1998.
Specifically, the Principles require that personal information:
- shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met,
- shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes,
- shall be adequate, relevant and not excessive in relation to those purpose(s),
- shall be accurate and, where necessary, kept up to date,
- shall not be kept for longer than is necessary,
- shall be processed in accordance with the rights of data subjects under the Act,
- shall be kept secure by the Data Controller who takes appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal information,
- shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal information.
The GHT will, through appropriate management, strict application of criteria and controls:
- observe fully conditions regarding the fair collection and use of information,
- meet its legal obligations to specify the purposes for which information is used,
- collect and process appropriate information, and only to the extent that it is needed to fulfil its operational needs or to comply with any legal requirements,
- ensure the quality of information used,
- ensure that the rights of people about whom information is held, can be fully exercised under the Act. (These include:
- the right to be informed that processing is being undertaken,
- the right of access to one’s personal information
- the right to prevent processing in certain circumstances and
- the right to correct, rectify, block or erase information which is regarded as wrong information),
- take appropriate technical and organisational security measures to safeguard personal information,
- ensure that data processing agreements are in place with all third parties who process the GHT’s data on their behalf and to include “sleepers” in all files of personal data that are passed to outside companies for processing,
- set out clear procedures for responding to requests for information.
5. Data Collection
5.1 Informed consent
Informed consent is when:
- a Data Subject clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data,
- and then gives their consent.
The GHT will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, by completing a form or submitting information on their website.
When collecting data, the GHT will ensure that the Data Subject:
- clearly understands why the information is needed,
- understands what it will be used for and what the consequences are should the Data Subject decide not to give consent to processing,
- as far as reasonably possible, grants explicit consent, either written or verbal for data to be processed
5.2 Personnel/employee administration
All contracts of employment for employees and contractors contain a clause giving permission for sensitive data to be held about them by the GHT.
6. Data Storage
Information and records will be stored securely and will only be accessible to authorised staff and volunteers.
Information will be stored for only as long as it is needed or required statute and will be disposed of appropriately.
It is the GHT's responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organisation which has been passed on/sold to a third party.
7. Data Security
All personal and sensitive data must be secure against unauthorised access. All PCs in use within the GHT will be password protected and any filing cabinets or other means of holding paper information will also be made secure. (Refer to IT Security and Control Policy)
8. Data Access and Accuracy
All Data Subjects have the right to access the information the GHT holds about them. The GHT will also take reasonable steps ensure that this information is kept up to date by asking data subjects whether there have been any changes.
In addition, the GHT will ensure that:
- it has a Data Protection Officer with specific responsibility for ensuring compliance with Data Protection,
- everyone processing personal information understands that they are contractually responsible for following good data protection practice,
- everyone processing personal information is appropriately trained to do so,
- anybody wanting to make enquiries about handling personal information knows what to do,
- it deals promptly and courteously with any enquiries about handling personal information,
- it describes clearly how it handles personal information,
- it will regularly review and audit the ways it hold, manage and use personal information,
- it regularly assesses and evaluates its methods and performance in relation to handling personal information,
- all staff are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them.
This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 1998.
In case of any queries or questions in relation to this policy please contact the GHT Data Protection Officer – The Church Administrator