Data Protection Policy
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Reviewed and updated; October 2019
Date of next review; October 2020
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Introduction
Tarner Community Project (TCP) is committed to being transparent about how it collects and uses the personal data of individuals, and to meeting its data protection obligations under the General Data Protection Regulations (GDPR) 2018. This policy sets out our commitment to data protection, and individual rights and obligations in relation to personal data and applies to the personal data of individuals processed by TCP.

The person with responsibility for data protection compliance within the organisation is Zarina Calver, HR Manager. If you have any questions about this policy, she can be contacted at Zarina@Tarner.org.uk .
Definitions
"Personal data" is any information that relates to a living individual who can be identified from that information.

“Processing” is any use that is made of data, including collecting, storing, amending, disclosing or destroying it.

"Special categories of personal data" means information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.

"Criminal records data" means information about an individual's criminal convictions and offences, and information relating to criminal allegations and proceedings.
Data protection principles
TCP processes personal data in accordance with the following data protection principles as outlined in the GDPR 2018:
• To process personal data lawfully, fairly and in a transparent manner.
• To collect personal data only for specified, explicit and legitimate purposes.
• To process personal data only where it is adequate, relevant and limited to what is necessary for the purposes of processing.
• To keep accurate personal data and take all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.
• To keep personal data only for the period necessary for processing.
• To adopt appropriate measures to make sure that personal data is secure, and protected against unauthorised or unlawful processing, and accidental loss, destruction or damage.

TCP keeps a record of its processing activities in respect of personal data in accordance with the requirements of the GDPR including the legal basis for processing the data which are:
1. Consent: an individual has given clear consent process their personal data for a specific purpose.
2. Contract: the processing is necessary for a contract with the individual, or because an individual has asked that specific steps are taken before entering into a contract.
3. Legal obligation: the processing is necessary for compliance with the law (not including contractual obligations).
4. Vital interests: the processing is necessary to protect someone’s life.
5. Public task: the processing is necessary to perform a task in the public interest or for official functions, and the task or function has a clear basis in law.
6. Legitimate interests: the processing is necessary for 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.

At TCP we tell individuals the reasons for processing their personal data, how we use such data and the legal basis for processing in our privacy notices. We will not process the personal data of individuals for other reasons. Where we rely on legitimate interests as the basis for processing data, we will carry out an assessment to ensure that those interests are not overridden by the rights and freedoms of individuals.

Personal data by us is held in hard copy or electronic format, or both, and on HR systems. Further details are provided in our privacy notices to individuals.

If an individual advises that their information has changed or is inaccurate, we will update it with undue delay. Employees of TCP are responsible for updating their contact details and absence information on the HR System, BreatheHR.
Individual rights
As a data subject, you have a number of rights in relation to your personal data.

Subject access requests
Individuals have the right to request confirmation that their data is being processed and information about how their data is being processed as well as access to, and copies of their data.

To make a subject access request, please complete a subject access request form (see appendix) and sent to Zarina@Tarner.org.uk.

TCP will normally respond to a request within a period of one month from the date it is received and no administrative charge is made. In some cases, such as where the request involves large amounts of data, we may respond within three months of the date the request is received, and it may incur a small administrative charge. If this is the case we will let you know as soon as possible.

Other rights
Individuals also have the right to require TCP to:
• rectify inaccurate data;
• stop processing or erase data that is no longer necessary for the purposes of processing;
• stop processing or erase data if the individual's interests override the organisation's legitimate grounds for processing data (where the organisation relies on its legitimate interests as a reason for processing data);
• stop processing or erase data if processing is unlawful; and
• stop processing data for a period if data is inaccurate or if there is a dispute about whether or not the individual's interests override the organisation's legitimate grounds for processing data.
To ask TCP to take any of these steps, you should send your request to Zarina@Tarner.org.uk.
Data security
TCP takes the security of personal data seriously. We have 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.

Where we engage 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.
Impact Assessments
If TCP processes data which may result in a high risk to an individual's rights and freedoms, we will carry out a data protection impact assessment to determine the necessity and proportionality of processing. This will include considering the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.
Data breaches
If we discover that there has been a breach of personal data that poses a risk to the rights and freedoms of individuals, we will report it to the Information Commissioner within 72 hours of discovery. We 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 also inform affected individuals and provide them with information about its likely consequences and mitigation measures that have been taken.
International data transfers
The organisation will not transfer personal data to countries outside the European Economic Area.
Individual responsibilities
Individuals are responsible for helping the organisation keep their personal data up to date.

Some individuals may have access to the personal data of other individuals and of our customers and clients in the course of their employment, contract or volunteer period. Where this is the case, TCP relies on them to help meet its data protection obligations.

Individuals who have access to personal data are required:
• to access only data that they have authority to access and only for authorised purposes;
• not to disclose data except to individuals (whether inside or outside the organisation) who have appropriate authorisation;
• to keep data secure (for example by complying with rules on access to premises, computer access, including password protection, and secure file storage and destruction);
• not to remove personal data, or devices containing or that can be used to access personal data, from the organisation's premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device;
• not to store personal data on local drives or on personal devices that are used for work purposes; and
• to report data breaches of which they become aware to Zarina Calver, HR Manager, immediately.

Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under the organisation's disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.
Training
TCP will provide training to all individuals about their data protection responsibilities as part of the induction process.

Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.
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