TRAUMA BRACHIAL PLEXUS GROUP
GENERAL DATA PROTECTION REGULATION: REGISTER OF SYSTEMS
Updated 10th January 2023
Introduction
In accordance with the General Data Protection Regulation which came into force on 25 May 2018, this document sets out the approach of TBPI Group to the collection, use and management of the personal data of its members under the following headings:
• The data we collect and in what way
• How the data is stored and who has access to it
• Sharing the data
• Purpose for which the data is used
• Data removal
The data we collect and in what way
On registering with TBPI Group, individuals are asked to complete an application form and to supply some basic details.
The data is entered on to an Excel spreadsheet by the Secretary and kept up to date by members notifying the charity of any changes.
How the data is stored and who has access to them
Only the committee secretary of the TBPI Group has access to the database.
The Excel spreadsheet maintained by the Secretary is kept on a charity laptop that is password protected.
The committee members can request information if it is relevant to a project or inquiry, although the individual will be contacted and permission sought to then pass the information on.
Members that are after support are able to put in a request to the charity to be connected to someone who fits their needs (due to location or medical history), permission will be sought from the ‘supporter’ to forward contact email to the ‘requestor’ before the data is shared.
Sharing the data
There is no requirement at this time to share the complete data set, and will not be shared with a third party unless legally obliged to do so.
Committee members have to go through the requests procedure above to gain access to any data.
From time to time it might be necessary to share the personal data of one member of TBPI Group with another in order, for example, to organise support via a physical meetup or phone call. This will not, however, be done, without the agreement of the member concerned.
Purpose for which the data are used
The data is processed on the basis of legitimate interest.
The data is used primarily as a vehicle for enabling support to TBPI Group members.
Data removal
Any individual that has registered with TBPI Group can contact a committee member for access to their data that is held and to also request their data to be permanently removed from the system.
Annual contact will be made to all of the individuals who’s data we hold to renew their permission for us to hold and use/share their data, if we do not receive a reply then their data is still held but no longer used/shared, after 3 failed annual emails their data is permanently removed from the data base.
Trauma Brachial Plexus Injury Group
Registered charity 1100691
Data Protection Policy
Last updated
31/12/2022
Definitions;
Charity – Means TBPI Group, a registered charity.
GDPR – Means the General Data Protection Regulation.
Responsible Person – Means Phillip Burke (Committee member).
Register of Systems – Means a register of all systems or contexts in which personal data is processed by the Charity.
1. Data protection principles
The Charity is committed to processing data in accordance with its responsibilities under the GDPR.
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.”
2. General provisions
a. This policy applies to all personal data processed by the Charity.
b. The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy.
c. This policy shall be reviewed at least annually.
3. Lawful, fair and transparent processing
a. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.
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 the charity shall be dealt with in a timely manner.
4. Lawful purposes
a. 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 (see ICO guidance for more information).
b. The Charity 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 Charity’s systems.
5. Data minimisation
a. The Charity shall ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
6. Accuracy
a. The Charity 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.
7. Archiving / removal
a. 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.
b. The archiving policy shall consider what data should/must be retained, for how long, and why.
8. Security
a. The Charity shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
b. 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.
c. When personal data is deleted this should be done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.
9. Breach
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, the Charity 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).
END OF POLICY