Base 51 Data Protection Policy
Approved: September 2019
Base 51 is committed to good practice compliance with Data Protection legislation and will process data in accordance with its responsibilities under the General Data Protection Regulations (GDPR)and Data Protection Act 2018.
Base 51 aims to prevent harm to individuals through the misuse or mismanagement of information about them. Active steps will be taken to ensure that individuals know enough about how their information is used or disclosed and that they have a genuine choice in these matters wherever reasonably possible.
Relevant Data Protection training will be included in all induction and training. All staff and volunteers working with personal data in any form have a responsibility to ensure that the principles of this policy are upheld. Internal audits of Data Protection compliance will be carried out at six monthly intervals.
2. Data Protection Principles Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals
b. 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
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
d. 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
e. 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
f. 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.
3. General provisions.
This policy applies to all personal data processed by Base 51
a. The Responsible Person (Chief Executive)shall take responsibility for the ongoing compliance with this policy for Base 51
b. The Board of Trustees will ensure that the Responsible Person is meeting compliance requirements by reviewing activity in this area on an annual basis
c. This policy shall be reviewed at least annually
d. Base 51 is registered with the Information Commissioner’s Office as an organisation that processes personal data
4. Lawful, fair and transparent processing
To ensure its processing of data is lawful, fair and transparent, Base 51shall
a. Maintain a Register of Systems recording what data is kept and why it is kept. This will be processed by the Office Manager.
b. The Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and any such requests made to Base 51 charity shall be dealt within one month of request.
5. Lawful purposes
a. All data processed by the charity must be done on one of the following lawful bases:
• Legal obligation
• Vital interests
• Public task
• Legitimate interests
b. Base 51 will record shall note the appropriate lawful basis in the Register of Systems
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data
d. 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 Base 51 Register of Systems.
6. Data minimisation
Base 51 will only keep personal data that is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
Base 51 keeps data on:
a. Membership forms will record data necessary to ensure the health and safety of the young person.
b. Membership forms will record data necessary to contact parents/carers in emergency.
c. Anonymised data will be collated for monitoring purposes. Where this is special category data, explicit consent will be sought before processing.
d. Information on the services young people use will be kept to ensure the right service is delivered for contractual purposes. Base 51 operates robust Safeguarding Policy and Procedures; Individual information and safeguarding referrals will be recorded securely on Lamplight (Case Management System)and shared appropriately.
a. Data is kept for the processing of payroll and to comply with legislation, for example DBS information, or other contractual obligations
b. HR information is retained securely during employment; information on ex-employees will be retained for as long as necessary to satisfy any contractual or legal requirements, including to protect against legal risk.
c. Contact details of employees; an emergency contact; and any medical or disability information is kept for Health and Safety Purposes
d. Training records; supervision notes; and appraisal notes are retained as evidence that both Base 51 and the employee are fulfilling their contractual obligations
a. Contact details of volunteers; an emergency contact; and any medical or disability information is kept for Health and Safety Purposes
b. Data is kept to comply with legislation, for example DBS information, or other contractual obligations
c. Volunteer information is retained securely during their volunteering period, information on ex-volunteers will be retained for as long as necessary to satisfy any contractual or legal requirements, including to protect against legal risk.
d. Training records and supervision notes are retained to ensure that volunteers are operating within Base 51 policies and procedures, and that the volunteer is receiving adequate support and guidance from the organisation
a. Details of individuals making donations to Base 51 will be recorded for audit purposes
b. Consent will be sought to keep information on donors, with options to opt out
7. Shared data with third parties
Data will be shared with third parties when there are:
a. Safeguarding concerns
b. Legal or contractual reasons
c. Consent. Any information shared will be recorded in case management files (Lamplight) and incident reports.
8. NET2 and imported data for monitoring
NET2 data is used to ensure correct information is recorded about young people using services. This enables parents/carers can be contacted in emergencies, any disabilities can be recorded so young people can use the building and service safely. Data will be anonymised from NET2 so Base 51 can report to funders of the services and review the use of services and the building. All members are asked to renew their membership on an annual basis, and any profiles not renewed will be archived or, where appropriate, deleted from Net 2.
a. Base 51 shall take reasonable steps to ensure personal data is accurate.
b. 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, with reviews each year of young peoples and employees information.
c. Lamplight is used to record young people’s use of services, outcomes and any safeguarding concerns and referrals. This will be reviewed periodically to ensure information is correct
d. Where Base 51 is advised that data is inaccurate, this will be rectified without delay, and any third parties with whom the data has been shared will also be notified
10. Archiving / removal
a. To ensure that personal data is kept for no longer than necessary, Base 51 shall put in place an archiving policy for each area in which personal data is processed and review this process annually
b. The archiving policy shall consider what data should/must be retained, for how long and why.
11.1 Personnel Data
a. Base 51shall ensure that personnel data is stored securely using modern software that is kept-up-to-date
b. Access to personnel data shall be limited to The Chief Executive, Deputy Chief Executive and Office Manager who need access. All data is kept securely in locked cabinets and password protected. The sharing of information will need to be authorised by the above.
c. When personnel data is deleted this will be done safely such that the data is irrecoverable.
d. Base 51 will have appropriate back-up and disaster recovery solutions in place.
11.2 Personal Data of Young People
a. All data that is processed by Base 51 is securely stored in our systems, and access is only granted to authorised workers.
b. All staff and volunteers who are involved with processing personal data are bound by the confidentiality policy and will not access, process or share data unnecessarily.
12. Data Systems
Systems for storing data such as Lamplight and NET2 are compliant with GDPR and password protected.
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, Base 51 shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO and, if deemed necessary, the individual/s affected by the breach.