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Data Protection Policy
- POLICY STATEMENT
Avon Riding Centre for the Disabled will:
- comply with both the law and good practice
- respect individuals’ rights
- be open and honest with individuals whose data is held
- provide training and support for staff and volunteers who handle personal data, so that they can act confidently and consistently.
The Centre recognises that its first priority under the Data Protection Act is to avoid causing harm to individuals. In the main this means:
- keeping this information securely, and
- holding accurate and appropriate information.
- PURPOSE AND BACKGROUND
In the course of carrying out its normal activities, Avon Riding Centre for the Disabled and its subsidiary company, Bristol Horse Riding, need to collect and use certain types of information about participants, their families and/or carers, volunteers, supporters and other individuals who come into contact with the Centre.
The purpose of this policy is to enable the Centre to:
- comply with the law in respect of data it holds about individuals;
- follow good practice;
- protect the Centre’s participants, volunteers, supporters and other individuals;
- protect the organisation from the consequences of a breach of its responsibilities.
This policy applies to information relating to identifiable individuals which is held by the Centre.
- DATA PROTECTION PRINCIPLES
The Centre regards the lawful and correct treatment of personal information as very important and therefore works to ensure that personal information is treated lawfully and correctly. To this end the Centre fully endorses and adheres to the Principles of Data Protection, as detailed in the Data Protection Act 1998.
Secondly, the Act aims to ensure that the legitimate concerns of individuals about the ways in which their data may be used are taken into account. In addition to being open and transparent, the Centre will seek to give individuals as much choice as is possible and reasonable, over what data is held and how it is used.
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 where stipulated,
- Shall be obtained only for one or more specified and lawful purposes, and shall not be further processed,
- Shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed,
- Shall be accurate and, where necessary, kept up to date,
- Shall not be kept for longer than is necessary for that purpose or those purposes,
- Shall be processed in accordance with the rights of data subjects under the Act,
- Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data,
- Shall not be transferred to a country or territory outside of the UK 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 data.
In order to meet the conditions set out above, the Centre will, through appropriate management, 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 operational needs or to comply with any legal requirements,
- ensure, as far as possible, the quality of information used,
- apply checks to determine the length of time information is held,
- 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 to access 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 (all personal information will either be stored in locked cabinets or on a secured and a suitably protected database),
- ensure that personal information is not transferred abroad without suitable safeguards,
- treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information,
- set out clear procedures for responding to requests for information.
In addition, the Centre will ensure that:
- there is someone with specific responsibility for Data Protection. The Centre’s Data Protection Officer is as listed at the end of this policy,
- everyone managing and handling personal information understands that they are responsible for following good data protection practice,
- everyone managing and handling personal information is appropriately supervised,
- queries about handling personal information are promptly and courteously dealt with,
- methods of handling personal information are clearly described,
- a regular review and audit is made of the way personal information is held, managed and used,
- methods of handling personal information are regularly assessed and evaluated,
- a breach of the rules and procedures identified in this policy by a member of staff or volunteer may lead to disciplinary action being taken.
More specific information about key areas is listed below.
- ACCURACY OF DATA
Avon Riding Centre may hold separate registers of their participants, volunteers and supporters.
Avon Riding Centre will, from time to time, review its procedures for ensuring that its records remain accurate and consistent and, in particular:
- IT systems will be designed, where possible, to encourage and facilitate the entry of accurate data.
- Data on any individual will be held in as few places as necessary, and all staff and volunteers will be discouraged from establishing unnecessary additional data sets.
- Effective procedures will be in place so that all relevant systems are updated when information about any individual changes.
Staff or volunteers who keep more detailed information about individuals will be given additional guidance on accuracy in record keeping.
- RETENTION OF DATA
The Centre will establish retention periods for at least the following categories of data:
Consent will normally not be sought for most processing of information about staff or volunteers, with the following exception:
- Staff details will only be disclosed for purposes unrelated to their work for the Centre (e.g. financial references) with their consent.
Information about volunteers will be made public according to their role e.g. Trustees, and consent will be sought for (a) the means of contact they prefer to be made public, and (b) any publication of information which is not essential for their role.
Information about participants and supporters will only be made public with their consent. (This includes photographs.)
‘Sensitive’ data about participants and supporters (including health information) will be held only with the knowledge and consent of the individual and access restricted to only those who need to be a user of such.
The Centre will treat the following direct communication with individuals as marketing:
- seeking donations and other financial support;
- promoting any services;
- promoting events;
- promoting forms of “membership” to supports;
- promoting sponsored events and other fundraising exercises;
- marketing on behalf of any external company or voluntary organisation.
Whenever data is first collected which might be used for any marketing purpose, this purpose will be made clear. The Centre will seek the Data Subject’s consent to such and the Data Subject will be given a clear opt in. If it is not possible to give a range of options, any opt-in which is exercised will apply to all of the Centre’s marketing.
The Centre has a policy of not sharing lists, with the exception of carrying out occasional joint mailings, where there is a clear affinity between parties, such joint mailings will only be carried out on a tightly-controlled basis.
The Centre undertakes to obtain external lists only where it can be guaranteed that the list is up to date and those on the list have been given an opportunity to opt in.
Data Controller for Avon Riding Centre is:
Tel: 0117 959 0266
When you request information from the Centre, sign up to any of our services or buy things from us, the Centre obtains information about you. This statement explains how we look after that information and what we do with it.
We have a legal duty under the Data Protection Act to prevent your information falling into the wrong hands. We must also ensure that the data we hold is accurate, adequate, relevant and not excessive.
Normally the only information we hold comes directly from you. Whenever we collect information from you, we will make it clear which information is required in order to provide you with the information, service or goods you needs. You do not have to provide us with any additional information unless you choose to. We store your information securely on our computer system, we restrict access to those who have a need to know, and we train our staff in handling the information securely. Hard copies of your information are stored in locked filing cabinets, again with restricted access.
You have the right to a copy of all the information we hold about you (apart from a very few things which we may be obliged to withhold because they concern other people as well as you). To obtain a copy, either ask for an application form to be sent to you, or write to the Data Protection Officer at the Centre.