Data Protection Policy
Data Protection Policy V2.0
1. The Data Protection Policy
Keelby Parish Council recognises its responsibility to comply with the General Data Protection Regulations (GDPR) 2018 which regulates the use of personal data. This does not have to be sensitive data; it can be as little as a name and address.
2. General Data Protection Regulations (GDPR)
The GDPR sets out high standards for the handling of personal information and protecting individuals’ rights for privacy. It also regulates how personal information can be collected, handled and used. The GDPR applies to anyone holding personal information about people, electronically or on paper. Keelby Parish Council has notified the Information Commissioner that it holds personal data about individuals.
When dealing with personal data, Keelby Parish Council staff and members must ensure that:
• Data is processed fairly, lawfully and in a transparent manner
This means that personal information should only be collected from individuals if staff have been open and honest about why they want the personal information.
• Data is processed for specified purposes only
This means that data is collected for specific, explicit and legitimate purposes only.
• Data is relevant to what it is needed for
Data will be monitored so that too much or too little is not kept; only data that is needed should be held.
• Data is accurate and kept up to date and is not kept longer than it is needed
Personal data should be accurate, if it is not it should be corrected. Data no longer needed will be shredded or securely disposed of.
• Data is processed in accordance with the rights of individuals
Individuals must be informed, upon request, of all the personal information held about them.
• Data is kept securely
There should be protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.
3. Purpose of this Document
This policy is to ensure that Keelby Parish Council complies with GDPR legislation. The policy applies to the personal data (for example:- current and former job applicants, employees, workers, contractors, and former employees, referred to as HR-related personal data) other personal data processed for Council business. . This policy does not apply to the personal data relating to members of the public.
The council has appointed the Clerk to the Council as the person with responsibility for data protection compliance within the Council. Questions about this policy, or requests for further information, should be directed to the Clerk.
4. Data Security and Storage
Keelby Parish Council recognises its responsibility to be open with people when taking personal details from them. This means that staff must be honest about why they want a particular piece of personal information.
Keelby Parish Council may hold personal information about individuals such as their names, addresses, email addresses and telephone numbers. These will be securely kept at the Keelby Parish Council Office and are not available for public access. All data stored on the Keelby Parish Council Office computers are password protected. Once data is not needed any more, is out of date or has served its use and falls outside the minimum retention time of Councils document retention policy, it will be shredded or securely deleted from the computer.
The council takes the security of personal data seriously. The council has internal policies and controls in place to protect personal data against loss, accidental destruction, misuse or disclosure, and to ensure that data is not accessed, except by employees in the proper performance of their duties. Relevant systems (e.g. eMail) used by Keelby Parish Council are appropriately registered with the Information Commissioner’s Office (ICO).
Where the council engages third parties to process personal data on our behalf, such parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
Duplicate records of personal data MUST NOT be kept by Council members, unless stored in officially registered systems (e.g. eMail) to support on-going business. Any such data will be deleted/returned to the Clerk on the completion of said business.
5. Data Breaches
The Council has robust measures in place to minimise and prevent data breaches from taking place. Should a breach of personal data occur the council must take notes and keep evidence of that breach.
If you are aware of a data breach you must contact the Clerk or Chairman of the Council immediately and keep any evidence, you have in relation to the breach. If the council discovers that there has been a breach of HR-related personal data that poses a risk to the rights and freedoms of yourself, we will report it to the Information Commissioner within 72 hours of discovery. The council will record all data breaches regardless of their effect.
If the breach is likely to result in a high risk to the rights and freedoms of individuals, we will tell you that there has been a breach and provide you with information about its likely consequences and the mitigation measures we have taken.
6. Accessing data
Keelby Parish Council is aware that people have the right to have access to any personal information that is held about them. Subject Access Requests (SARs) must be submitted in writing (this can be done in hard copy, email or social media). If a person requests to see any data that is being held about them, the SAR response must detail:
• How and to what purpose personal data is processed
• The period Keelby Parish Council tend to process it for
• Anyone who has access to the personal data
The response must be sent within 30 days and should be free of charge.
If a SAR includes personal data of other individuals, Keelby Parish Council must not disclose the personal information of the other individual. That individual’s personal information may either be redacted, or the individual may be contacted to give permission for their information to be shared with the Subject. Individuals have the right to have their data rectified if it is incorrect, the right to request erasure of the data, the right to request restriction of processing of the data and the right to object to data processing, although rules do apply to those requests. Please see “Subject Access Request Procedure” published by the ICO for more details.
7. Confidentiality
Keelby Parish Council members and staff must be aware that when complaints or queries are made, they must remain confidential unless the subject gives permission otherwise. When handling personal data, this must also remain confidential.