CHRISTIAN HOPE UGANDA (UK)

(Referred to throughout this document as CHU)

 

Definitions

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Charity means CHRISTIAN HOPE UGANDA (UK)

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GDPR means the General Data Protection Regulation

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Responsible Person means Peter Frith

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Register of Systems means a register of all systems or contexts in which personal data is processed by the Charity as documented in the check list. (Please see section 1 of the Privacy Policy. )

 

1. Data protection principles

          The Charity is committed to processing data in accordance with its responsibilities under the GDPR. 

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      Article 5 of the GDPR requires that personal data shall be:

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1. processed lawfully, fairly and in a transparent manner in relation to individuals;

2. 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;

3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

4. accurate and, where necessary, kept up to date; every reasonable step will 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;

5. 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 organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.”

 

2. General provisions

1. This policy applies to all personal data processed by the Charity. 

2. The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy. 

3. This policy shall be reviewed at least annually. 

 

3. Lawful, fair and transparent processing 

1. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems. 

2. The Register of Systems shall be reviewed at least annually. 

3. Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner. 

 

4. Lawful purposes

1. All data processed by the charity will 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). 

2. The Charity shall note the appropriate lawful basis in the Register of Systems.

3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data. 

4. 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 the Charity’s systems.  

 

5. Data minimization

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

2. Data that is being stored and collected will be cross matched with the check list to ensure only the minimum data needed is being stored.

 

6. Accuracy

1. The Charity 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. Any changes or errors in data will be corrected as soon as possible

 

7. Archiving / removal

1. The charity will  ensure that personal data is kept for no longer than necessary 

2. CHU will not be archiving data. Data that is no longer needed will be deleted from computer files, backups and shredded if in paper forms.

3. Our data protection policy will be reviewed annually to ensure that personal data is removed as and when it is no longer needed. 

 

8. Security

1. The Charity shall ensure that personal data is stored securely using modern software that is kept-up-to-date.  

2. Access to personal data is be limited to personnel who need access and appropriate security is in place to avoid unauthorized sharing of information. 

3. When personal data is deleted this shall be done safely such that the data is irrecoverable. 

4. Appropriate back-up and disaster recovery solutions are in place. 

 

9. Breach

        In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration,                          unauthorized disclosure of, or access to, personal data, the Charity shall promptly assess the risk to people’s            rights and freedoms and if appropriate report this breach to the ICO.     https://ico.org.uk/

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Last updated 12th October 2021

 

This policy was adopted by the trustees on 12th October 2021

 

 

(We are grateful to White Fuse for the template on which this policy is based.)