Privacy Policy

Data Protection Policy

Last updated:       March, 2018

Definitions

Charity means The Biscuit Fund, a registered charity.

GDPR means the General Data Protection Regulation.

Responsible Person means Jenni Bickerdyke.

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:

  • processed lawfully, fairly and in a transparent manner in relation to individuals;
  • 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;
  • adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  • 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;
  • 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
  • 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

  • This policy applies to all personal data processed by the Charity.
  • The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy.
  • This policy shall be reviewed at least annually.
  • The Charity shall register with the Information Commissioner’s Office as an organisation that processes personal data.

3. Lawful, fair and transparent processing

  • To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.
  • The Register of Systems shall be reviewed at least annually.
  • 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

  • All data processed by the charity must be done on one of the following lawful bases:
  • (i) Consent: the individual has given clear consent for you to process their personal data for a specific purpose
  • (ii) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
  • (iii) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).
  • (iv) Vital interests: the processing is necessary to protect someone’s life.
  • (v) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
  • (vi) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are public authority processing data to perform your official tasks.)
  • The Charity shall note the appropriate lawful basis in the Register of Systems.
  • Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
  • 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

  • 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.

6. Accuracy

  • The Charity shall take reasonable steps to ensure personal data is accurate.
  • 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

  • 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 regularly.
  • The archiving policy shall consider what data should/must be retained, for how long, and why.

8. Security

  • The Charity shall ensure that personal data is stored securely using modern software that is kept up to date.
  • 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.
  • When personal data is deleted this should be done safely such that the data is irrecoverable.
  • 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
Note about the policy template that this policy is based on: Lots of template policies are unhelpfully long and simply reiterate large portions of the legislation. This template is different: it aims to provide a concise and practical document that can be used by trustees of small charities as the foundation for a working Data Protection Policy. If you have any doubt about your legal obligations you should always check with a lawyer.

Our website address is: https://www.biscuitfund.org.

What personal data we collect and why we collect it

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Analytics

Who we share your data with

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

Your contact information

Additional information

How we protect your data

What data breach procedures we have in place

What third parties we receive data from

What automated decision making and/or profiling we do with user data

Industry regulatory disclosure requirements