ICYE-UK GDPR Policy
Date of next Policy Review: April 2020
ICYE UK is committed to processing data in accordance with its responsibilities under the GDPR.
1. Data protection principles
Article 5 of the GDPR requires that personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
2. General provisions
- This policy applies to all personal data processed by ICYE UK.
- The Responsible Person shall take responsibility for ICYE UK’s ongoing compliance with this policy by ensuring that data is kept secure and is held for no longer than 6 years.
- This policy shall be reviewed at least annually in order to ensure ICYE UK remains compliant.
- ICYE UK shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
- To ensure its processing of data is lawful, fair and transparent, ICYE UK shall maintain a clear and accessible Register of Systems.
- The Register of Systems shall be reviewed at least annually to ensure that data held is compliant with GDPR regulations and will not hold data for longer than a period of six years.
- Individuals have the right to access their personal data at any time and any such requests made to the charity shall be dealt with in a timely manner. ICYE UK commits to respond to requests within one week during usual office hours.
4. Lawful purposes
- All data processed by ICYE UK must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
- ICYE UK shall note the appropriate lawful basis for holding data in the Register of Systems.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data and ICYE UK will ensure that consent is given for data to be shared with country offices.
- When communications are sent to individuals based on their consent, the option for the individual to withdraw their consent will be clearly available and systems will be in place to ensure such withdrawal is reflected accurately in ICYE UK’s systems.
5. Data minimisation
- ICYE UK shall ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- When collecting data to be shared with other country offices who will not be GDPR compliant, ICYE UK will ensure that any personal data is secured on password protected documents.
- ICYE UK shall take reasonable steps to ensure personal data is accurate by verifying data on register a minimum of every 3 years.
- 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.
7. Archiving / removal
- To ensure that personal data is kept for no longer than necessary, ICYE UK shall put in place a clear archiving process for each area in which personal data is processed and review this data annually to ensure data held is within the six-year maximum.
- ICYE UK shall ensure that personal data is stored securely using software that is kept-up-to-date and password protected.
- Access to personal data shall be limited to persons who need access and appropriate security will be in place to avoid unauthorised sharing of information, staff will not share information with third party organisations unless having prior consent from individuals.
- When personal data is deleted or destroyed this should be done safely such that the data is irrecoverable.
- Appropriate back-up and recovery solutions shall be in place and all data held on software will be backed up on password protected external devices in the event of software failure.
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, ICYE UK 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).