GDPR

Data Protection Policy

Wembley Christian Fellowship (WCF)

(Registered charity No: 1139705. Registered in England and Wales)

Version: 1

Date: 1st January, 2019

 

Definitions

WCF Wembley Christian Fellowship
Charity Wembley Christian Fellowship
GDPR General Data Protection Regulation
Responsible Person (Data Protection Officer) Mr Chalin Jacob
Record Type Encrypted Microsoft Spreadsheet & Word / PDF files / Hard copy of documents.

 

1. YOUR PERSONAL DATA THAT WE HOLD

Any data, which include contact details, paper and electronic documents, photos and videos. by which a person’s privacy can be compromised, or by which a person can be identified. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).

 

2. HOW DO WE PROCESS YOUR PERSONAL DATA?

WCF complies with its obligations under the “GDPR” by keeping personal 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.

We use your personal data for the following purposes:

  1. To fund raise and promote the interests of the charity.
  2. To maintain our own accounts and records (including the processing of gift aid applications).
  3. To inform you of news, events, activities, essential information and services running at WCF.
  4. To share appropriate details with the HMRC for the purposes of administering the Gift Aid Scheme, which benefits WCF by returning tax to the charity.
  5. Carry out DBS checks where necessary.

 

3. GENERAL PROVISIONS

  1. This policy applies to all personal data processed by WCF.
  2. The Responsible Person (Data Protection Officer) shall take responsibility for WCF’s ongoing compliance with this policy.
  3. To inform you of news, events, activities, essential information and services running at WCF.
  4. This policy shall be reviewed at least annually.

 

4. LAWFUL, FAIR AND TRANSPARENT PROCESSING

  1. To ensure its processing of data is lawful, fair and transparent, WCF shall maintain a well-structured encrypted Microsoft Spreadsheet & Word docs, PDF Files and safe storage of Hard Copy.
  2. The encrypted Microsoft Spreadsheet & Word docs, PDF Files & Hard copies shall be reviewed every two years.
  3. Explicit consent of the data subject so that we can keep you informed about news, events, activities and services and process your gift aid donations.
  4. WCF shall note the appropriate lawful basis in the encrypted Microsoft Spreadsheet & Word docs, PDF Files and safe storage of Hard Copy.
  5. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
  6. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in WCF’s systems.

 

5. DATA MINIMISATION

WCF shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

 

6. ACCURACY

  1. WCF shall take reasonable steps to ensure personal data is accurate.
  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
  3. The delegates and team members of WCF are responsible to provide the Data Protection Officer with the right/updated information, should there be any amendments to your personal data.
  4. To a certain extent, the accuracy of the personal data depends on how accurately the data are provided by the respective person.

 

7. ARCHIVING / REMOVAL

  1. Specifically, we retain gift aid declarations and associated paperwork permanently.
  2. Other records, which don’t need to be permanently stored, will be destroyed every 7 years. Audit trials will be maintained for this.

 

8. SHARING PERSONAL DATA

  1. The personal data will be treated strictly and confidentially – the data will only be shared where needed with the members of WCF, in relating to carrying out Charity related activities.
  2. Your personal data will only be shared to third parties with your consent.
  3. You are not allowed to compromise the reputation of the Charity or any other members of the Charity by publishing any kind of data related to the Charity or members of the Charity, including documents, photos or videos.
  4. You can only publish a confidential data of another member of the Charity, in Social Media, including their individual photos, with the respective person’s consent.

 

9. YOUR RIGHTS AND YOUR PERSONAL DATA

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

  1. The right to request a copy of your personal data which WCF holds about you;
  2. The right to request that the Data Protection Officer and Trustees of WCF corrects any personal data if it is found to be inaccurate or out of date;
  3. The right to request your personal data is erased where it is no longer necessary for WCF, to retain such data;
  4. The right to withdraw your consent to the processing at any time provided it doesn’t contravene any statutory requirements of WCF.
  5. The right to request that the Data Protection Officer provide the data subject with his/her personal data and where possible, to transmit that data directly to another Data Protection Officer
  6. 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;
  7. The right to lodge a complaint with the Information Commissioners Office.

 

10. FURTHER PROCESSING

If we wish to use your personal data for a new purpose, not covered by this Policy, 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.

 

11. SECURITY

  1. WCF shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
  2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
  3. Members of the WCF are requested in writing, to securely delete or hand over any confidential/personal data, that does not belong to them, to the Data Protection Officer
  4. When personal data is deleted this shall be done safely such that the data is irrecoverable.
  5. WCF will ensure that appropriate back-up and disaster recovery solutions shall be in place.

 

12. BREACH

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

 

13. COMPLAINTS / QUERIES

WCF aims to achieve the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this subject very seriously. We encourage you to contact us by email (contact@wembleychristianfellowship.com) if you think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome your suggestions for improving our procedures. This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of WCF’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to WCF’s Data Protection Officer.

 

14. CHANGES TO THIS PRIVACY NOTICE

We keep our privacy notice under regular review. This privacy notice was created on 1st, January, 2019. Useful link from ICO explaining GDPR – https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/

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