Data Protection:

Network Data Protection GDPR and UK Data Protection Compliance & Implementation Policy

Network GDPR and UK Data Protection compliance involves exclusively — given the nature of the Network’s activity and services delivery provision — email context information transfer on email address and email content particulars between the Network and Network partners and Network service provision service users, and between Network team members (trustees, advisors, general volunteers). 

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Network Data protection principles:

The LGBT+ Network for Change (hereafter in this document/policy referred to as the ‘Network’) is committed to processing data in accordance with its responsibilities under the GDPR.

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

  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 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;
  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 organisational 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 unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
General provisions:
  1. This policy applies to all personal data processed by the Network.
  2. The Responsible Person (Network operational lead) shall take responsibility for the Network’s ongoing compliance with this policy.
  3. This policy is reviewed annually.
Lawful purposes:
  1. All data processed by the charity must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests – reference: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/.
  2. The Network will accept 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 exists.
Data minimisation:

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

Accuracy:

  1. The Network will 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.
Archiving and/or removal:
  1. To ensure that personal data is kept for no longer than necessary, the Charity shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
  2. The archiving policy shall consider what data should/must be retained, for how long, and why.
Security:
  1. The Network will 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. When personal data is deleted this will be done safely so that the data is irrecoverable.

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Designated GDPR and Data Compliance Officer  and Network team members assistive roles concerning policy compliance and implementation: 

The Network operational lead has overall responsibility for GDPR and UK ICO (Information Commission Office) Data Protection compliance, with all Network team (trustees, advisors, volunteers members) supporting the Network operational lead in regard to GDPR and Data Protection compliance by the Network, as outside of Network Operational Lead – Network partners and Network LGBT+ community service users email interactions, the vast majority of Network email interactions are Network trustee, advisor, general volunteer Network services delivery related.