Hinckley Canoe Club Data Protection Policy

POLICY STATEMENT

Everyone has rights with regard to the way in which their personal data in handled. During the course
of our activities we will collect, store and process personal data about our members, and we recognise
that the correct and lawful treatment of this data will maintain confidence in the club.
Data Users are obliged to comply with this policy when processing personal data on our behalf. Any
breach of this policy may result in disciplinary action.

ABOUT THIS POLICY

The types of personal data that Hinckley Canoe Club (We) may be required to handle include
information about current, past and prospective members. The personal data, which may be held on
paper or on a computer or other media, is subject to certain legal safeguards specified in the Data
Protection Act 2018 (the Act) and other regulations.
This policy and any other documents referred to in it sets out the basis on which we will process any
personal data we collect from data subjects, or that is provided to us by data subjects or other sources.
This policy may be amended at any time.
This policy sets out rules on data protection and the legal conditions that must be satisfied when we
obtain, handle, process, transfer and store personal data.
The Data Protection Officer is responsible for ensuring compliance with the Act and with this policy.
This post is held by the Membership Secretary (membership@hinckleycanoeclub.co.uk). Any
questions about the operation of this policy or any concerns that the policy has not been followed
should be referred in the first instance to the Data Protection Officer.
DEFINITION OF DATA PROTECTION TERMS
Data is information which is stored electronically, on a computer, or in certain paper-based filing
systems.
Data subjects for the purpose of this policy include all living individuals about whom we hold personal
data. A data subject need not be a UK national or resident.
All data subjects have legal rights in relation to their personal information.
Personal data means data relating to a living individual who can be identified from that data (or from
that data and other information in our possession). Personal data can be factual (for example, a name,
address or date of birth) or it can be an opinion about that person, their actions and behaviour.
Data controllers are the people who or organisations which determine the purposes for which, and
the manner in which, any personal data is processed. They are responsible for establishing practices
and policies in line with the Act. We are the data controller of all personal data used in our club for
our own club purposes.
Data users are those on the committee whose role involves processing personal data. Data users must
protect the data they handle in accordance with this data protection policy and any applicable data
security procedures at all times.
Data processors include any person or organisation that is not a data user that processes personal
data on our behalf and on our instructions. Employees of data controllers are excluded from this
definition but it could include suppliers which handle personal data on British Canoeing’s behalf.
Processing is any activity that involves use of the data. It includes obtaining, recording or holding the
data, or carrying out any operation or set of operations on the data including organising, amending,
retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal
data to third parties.
Sensitive personal data includes information about a person's racial or ethnic origin, political opinions,
religious or similar beliefs, trade union membership, physical or mental health or condition or sexual
life, or about the commission of, or proceedings for, any offence committed or alleged to have been
committed by that person, the disposal of such proceedings or the sentence of any court in such
proceedings. Sensitive personal data can only be processed under strict conditions, including a
condition requiring the express permission of the person concerned.
DATA PROTECTION PRINCIPLES
Anyone processing personal data must comply with the eight enforceable principles of good practice.
These provide that personal data must be:
? Processed fairly and lawfully
? Processed for limited purposes and in an appropriate way
? Adequate, relevant and not excessive for the purpose
? Accurate
? Not kept longer than necessary for the purpose
? Processed in line with data subjects' rights
? Secure
? Not transferred to people or organisations situated in countries without adequate protection
FAIR AND LAWFUL PROCESSING
The Act is not intended to prevent the processing of personal data, but to ensure that it is done fairly
and without adversely affecting the rights of the data subject.
For personal data to be processed lawfully, they must be processed on the basis of one of the legal
grounds set out in the Act. These include, among other things, the data subject's consent to the
processing, or that the processing is necessary for the performance of a contract with the data subject,
for the compliance with a legal obligation to which the data controller is subject, or for the legitimate
interest of the data controller or the party to whom the data is disclosed. When sensitive personal
data is being processed, additional conditions must be met. When processing personal data as data
controllers in the course of our business, we will ensure that those requirements are met.
PROCESSING FOR LIMITED PURPOSES
In the course of our business, we may collect and process the personal data set out in the Schedule.
This may include data we receive directly from a data subject (for example, by completing forms or by
corresponding with us by mail, phone, email or otherwise) and data we receive from other sources.
We will only process personal data for the specific purposes set out in the Schedule or for any other
purposes specifically permitted by the Act. We will notify those purposes to the data subject when we
first collect the data or as soon as possible thereafter.
NOTIFYING DATA SUBJECTS
If we collect personal data directly from data subjects, we will inform them about:
? The purpose or purposes for which we intend to process that personal data
? The types of third parties, if any, with which we will share or to which we will disclose that
personal data
? The means, if any, by which data subjects can limit our use and disclosure of their personal
data
? If we receive personal data about a data subject from other sources, we will provide the data
subject with this information as soon as possible thereafter
We will also inform data subjects whose personal data we process that we are the Data Controller
with regard to that data.
ADEQUATE, RELEVANT AND NON-EXCESSIVE PROCESSING
We will only collect personal data to the extent that it is required for the specific purpose notified to
the data subject.
ACCURATE DATA
All members are responsible for checking that any information they provide to the club in connection
with their membership is accurate and up to date and for informing the club of any changes to the
information they have provided e.g. changes of address, either at the time of joining or subsequently.
More generally, we will ensure that personal data we hold is accurate and kept up to date. We will
check the accuracy of any personal data at the point of collection and at regular intervals afterwards.
We will take all reasonable steps to destroy or amend inaccurate or out of date data.
TIMELY PROCESSING
We will not keep personal data longer than is necessary for the purpose or purposes for which they
were collected. We will take all reasonable steps to destroy, or erase from our systems, all data which
is no longer required.
PROCESSING IN LINE WITH DATA SUBJECT’S RIGHTS
We will process all personal data in line with data subjects' rights, in particular their right to:
? Request access to any data held about them by a data controller
? Prevent the processing of their data for direct-marketing purposes
? Ask to have inaccurate data amended
? Prevent processing that is likely to cause damage or distress to themselves or anyone else
DATA SECURITY
We will take appropriate security measures against unlawful or unauthorized processing of personal
data, and against the accidental loss of, or damage to, personal data.
We will put in place procedures and technologies to maintain the security of all personal data from
the point of collection to the point of destruction. Personal data will only be transferred to a data
processor if he agrees to comply with those procedures and policies, or if he puts in place adequate
measures himself.
We will maintain data security by protecting the confidentiality, integrity and availability of the
personal data, defined as follows:
? Confidentiality means that only people who are authorised to use the data can access it.
? Integrity means that personal data should be accurate and suitable for the purpose for which
it is processed.
? Availability means that authorised users should be able to access the data if they need it for
authorised purposes. Personal data should therefore be stored on the Hinckley Canoe Club
Google Drive instead of individual PCs.
Security procedures include:
Entry controls. Any stranger seen in entry-controlled areas should be reported.
Secure lockable desks and cupboards. Desks and cupboards should be kept locked if they hold
confidential information of any kind (personal information is always considered confidential).
Methods of disposal. Paper documents should be shredded. Digital storage devices should be
physically destroyed when they are no longer required.
Equipment. Data users must ensure that individual monitors do not show confidential information to
passers-by and that they log off from their PC when it is left unattended.
Passwords and encryption of computerised personal data. If it is computerised, the personal data
should be coded, encrypted or password protected both on a local hard drive and on a network drive
that is regularly backed up. If a copy is kept on removable storage media, that media must itself be
kept in a locked filing cabinet, drawer, or safe.
All committee members are responsible for ensuring that any personal data they hold is kept securely
and that it is not disclosed either orally or in writing or via web pages or by any other means,
accidentally or otherwise, to any unauthorised third party.
DISCLOSURE AND SHARING OF PERSONAL INFORMATION
We may share personal data we hold with any member of the committee.
We may also disclose personal data we hold to third parties:
If we are under a duty to disclose or share a data subject's personal data in order to comply
with any legal obligation, or in order to enforce or apply any contract with the data subject or
other agreements; or to protect our rights, property, or safety of our members or others.
We may also share personal data we hold with selected third parties for the purposes set out
in the Schedule.
DEALING WITH SUBJECT ACCESS REQUESTS
Data subjects may make a request for information we hold about them to the Data Protection Officer.
When receiving telephone enquiries, we will only disclose personal data we hold on our systems if the
following conditions are met:
? We will check the caller's identity to make sure that information is only given to a person who
is entitled to it.
? We will suggest that the caller put their request in writing if we are not sure about the caller’s
identity and where their identity cannot be checked.
? Committee Members will refer a request to Data Protection Officer for assistance in difficult
situations.
? Committee Members should not be bullied into disclosing personal information.
DISASTER RECOVERY
We store data on Google Drive which is backed up automatically and is protected by firewalls and
virus checkers.
CHANGES TO THIS POLICY
We reserve the right to change this policy at any time. Where appropriate, we will notify data subjects
of those changes by mail or email.
DATA RETENTION
Data will be stored by us in line with the above policy.