Data Protection Policy
Jan 2019(Review Date: Jan 2020)
Data Protection Policy
Signed: Mark Cowling, Trustee
Introduction and Scope
The Role and Responsibilities of Designated Person(s)
1. Introduction and Scope
Your personal data – what is it?
Personal data relates to a living individual who can be identified from that
data. Identification can be by the information alone or in conjunction with any otherinformation in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by General Data Protection
Regulation (the ‘GDPR’).
All enquiries should be directed to:
The Role & Responsibilities of Designated Persons
Third Space Designated Person for Data Protection:
Name: Status: Contact:
Associate Minister, Bolton Parish Church
The role of designated person(s) within Third Space is to:
Oversee data control. This means it decides how your personal data is processed and for what purposes. Third Space Bolton may change this policy from time to time and any such changes will be published on our website. Notwithstanding any change to this policy, we will continue to process your personal data in accordance with your rights and our obligations in law.
3. Policy statement
How do we process your personal data?
We collect data necessary for Third Space Bolton to pursue its stated charitable objectives, and by running events, maintaining memberships, keep our members and supporters informed of our activities, marketing, fundraising and the effective
running of Third Space Bolton through its staff, trustees and volunteers.
Third Space Bolton complies with its obligations under the “GDPR” by keepingpersonal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse,
unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
In furtherance of this we use your personal data, which includes but is not limited to the following purposes: –
• to enable Third Space to provide voluntary services for the benefit of the public in our local community;
- Safeguarding casework and safer recruitment work;
- Fulfilling obligations under Health & Safety legislation;
- Conference/events management;
- Issuing and arranging the distribution of publications, mailings and newsletters;
- Enabling people to participate in campaigns/allowing the administration of campaigns;
- Communication with existing/new/potential supporters of Third Space about enquiries relating to giving to/fundraising on behalf and promoting the interests of Third Space;
- To respond to general enquiries.
Data collected and processed may include, but not be limited to:
• Sensitive data may be collected where necessary for safeguarding purposes, or for employment purposes, or where required by law. Article 9 GDPR defines sensitive data as information about an individual’s race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life, or sexual orientation.
What is the legal basis for processing your personal data?
Organisations are permitted to process data if they have a legal basis for doing so. Third Space Bolton processes data on the basis that:
- Third Space Bolton has a legitimate interest to process data; and/or
- Express and informed consent has been given by the person whose data is being
• It is necessary in relation to a contract or agreement which the person has entered
into or because the person has asked for something to be done so they can enter into a contract or agreement; and/or
- There is a legal obligation on Third Space Bolton to process data; and/or
- Processing is necessary to protect the vital interests of a data subject or anotherperson (in accordance with safeguarding policy and practice).
Where we process special category sensitive data (under Article 9 of the GDPR) we process data on the basis that:
• Explicit consent has been given by the person whose data is being processed; and/or
• It is necessary for Third Space Bolton to carrying out its obligations under employment, social security or social protection law, or a collective agreement;
• Processing is necessary to protect the vital interests of a data subject or another
individual where the data subject is physically or legally incapable of giving consent; (in accordance with safeguarding policy and practice); and/or
- Third Space Bolton is a membership organisation and the processing relates only to members or former members or those who have regular contact with it in connection with its purposes, and no disclosure is made to a third party without consent of the person whose data is being processed; and/or
- Processing is necessary for archiving purposes in the public interest, or scientific and historical research purposes or statistical purposes.
Sharing your personal data
Your data will not be shared outside of Third Space Bolton, except where required to do so by law, or with trusted third parties where necessary to communicate with our
members, office holders and volunteers (such as mailing companies for postal communications or through small email campaigns or newsletters), and only once
satisfied that any such use of data will accord with this policy. Explicit, informed consent will be sought from individuals whenever and wherever required in accordance with data protection legislation.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the data we process. Users of our web-based applications are responsible for keeping passwords confidential. We will only ask users for passwords for IT support purposes.
How long do we keep your personal data?
We retain data in paper or electronic format on the following basis: We regularly
review the data we hold and securely delete any personal data that is no longer necessary for us to process.
Members and friends contact details Gift aid declarations and paperwork
Personal data relating to events for which additional information is gathered eg Youth Club Trips
Records of attendance of children/young people and helpers
Photographs and videos of events
Insurance Records Safeguarding matters
Complaints (non -safeguarding)
Pension Records (money purchase) Day Nursery records
Housing Resident records
Rejected Job Applicant records
Applications of successful candidates, Employment contracts, changes to terms and conditions, copies of identification documents, performance and training records, Redundancy records
Disclosure & Barring Service Certificate number and date
24 months after the last contact
6 years after the calendar year to which it relates
Disposed of immediately after the event unless anything has occurred (eg an accident) which indicates that records should be retained for a longer period.
Indefinitely for safeguarding purposes
24 months after the event – selected items retained for historical records
Indefinitely or until advised otherwise by authorities
3 years from the date of the last entry (or, if the accident involves a child/ young adult, then until that person reaches the age of 21)
3 years after resolution of complaint (unless further action is anticipated)
6 years after the date of termination of employment 6 years after transfer or value taken
6 years after child leaves our nursery
6 years after resident leaves our accommodation
6 months after applicant is notified of rejection
50 years after employment ceases
50 years after employment / volunteering ceases
Employee Annual leave, sickness, parental leave, return to work records. Records for the purposes of tax returns including wage or salary records, records of overtime, bonuses and expenses.
6 years after end of each tax year
Pay as you earn records, income tax returns, NI, Correspondence with HMRC, National Minimum Wage compliance records, Statutory Sick Pay records. Statutory maternity, paternity and shared parental pay records, calculations, certificates or other evidence. Records relating to hours worked and payments made to workers
3 years after the end of the financial year to which they relate
Details of employee benefits in kind, income tax
records (P45, P60, P58, P48 etc), annual return of 4 years after end of each tax year taxable pay and tax paid.
Records of reportable injuries, diseases or
dangerous occurrences. Injury arising out of 3 years from date of the entry accident at work
Lists or register of employees who have been exposed to asbestos dust, including health records of each employee. Medical records and details of biological tests under the Control of Lead at Work Regulations. Medical records as specified by the Control of Substances Hazardous to Health Regulations (COSHH). Records of monitoring of exposures to hazardous substances (where exposure monitoring is required under COSHH)
40 years from the date of the last entry made in the record
Records of tests and examinations of control systems and protective equipment under COSHH
5 years from the date on which the record was made
We Your rights and your personal data
respect to your personal data: –
• The right to request a copy of your personal data which Third Space Bolton holds
about you (a Subject Access Request or ‘SAR’);;
• The right to request that Third Space Bolton corrects any personal data if it is found
to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary forThird Space Bolton to retain such data. (Records will remain in skeleton, to ensureno further contact in future);
- The right to withdraw your consent to the processing at any time
- The right to request that the data controller provide the data subject with his/herpersonal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable) [Only applies where the processing is based on consent or is necessary for the performance of a contract with the data subject and in either case the data controller processes the data by automated means].
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable) [Only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics]
- The right to lodge a complaint with the Information Commissioner’s Office.
You can contact the Fundraising Regulator on 0300 999 3407 or via email: email@example.com or at Fundraising Regulator, 2nd Floor, CAN Mezzanine Building, 49 – 51 East Road, London N1 6AH.
If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and
processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
To exercise all relevant rights, queries of complaints please in the first instance contact the Data Protection Officer at firstname.lastname@example.org or Data Protection, Third Space Bolton, 133 Deasngate, Bolton BL1 1HA.
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