General Data Protection Regulation (GDPR) Policy
We hold personal data about our employees, members, clients, suppliers and other individuals for a variety of business purposes.
This policy sets out how we seek to protect personal data and ensure that staff/members understand the rules governing their use of personal data to which they have access in the course of their work. In particular, this policy requires staff/members to ensure that the Data Protection Officer (DPO)(Chairman or named of DPA) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.
What is GDPR?
Keeping information about clients and staff/members confidential makes clear business sense but it is also required by law. The EU General Data Protection Regulation (GDPR) defines the ethical handling of personal data. Replacing legislation written before the digital age, the regulation became EU law in 2016, enforceable from 25th May, 2018.
The purposes for which personal data may be used by us:
Personnel, administrative, financial, regulatory, payroll and business development purposes.
Business purposes include the following:
Information relating to identifiable individuals, such as job applicants, current and former employees, agency, members, Directors, contractors and other staff, clients, suppliers and marketing contacts.
Personal data we gather may include: individuals’ contact details, educational background, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, job title, and CV.
Personal data about an individual’s racial or ethnic origin, political opinions, religious or similar beliefs, membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings—any use of sensitive personal data should be strictly controlled in accordance with this policy. This can include subcontractors and agents. Processors must maintain records of personal data and processing activities and will have legal liability if responsible for a breach.
An organisation that determines the way in which personal data is processed. The controller must be able to demonstrate compliance with the principles and ensure contracts with data processors comply with the GDPR. Company secretary or accountant.
Collecting, disclosing, storing, using or any other operation performed upon personal data. If you use personal data in any way you will be “processing” it.
This policy applies to all members.
This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time.
Who is responsible for this policy?
ProAm Champions Ltd has overall responsibility for the day-to-day implementation of this policy.
Fair and lawful processing
We must process personal data fairly and lawfully in accordance with individuals’ rights. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening.
ProAm Champions Ltd are:
Responsibilities of the IT Services (third party)
Responsibilities of the Accountant (third party)
The processing of all data must be:
Our Terms of Business contains a Privacy Notice to clients on data protection. The notice:
Sensitive personal data
In most cases where we process sensitive personal data we will require the data subject’s explicit consent to do this unless exceptional circumstances apply or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.
Accuracy and relevance
We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose.
Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO.
Your personal data
You must take reasonable steps to ensure that personal data we hold about you is accurate and updated as required. For example, if your personal circumstances change, please inform ProAm Champions Ltd so that they can update your records.
You must keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, ProAm Champions Ltd will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.
Storing data securely
We must retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, considering the reasons that the personal data was obtained, but should be determined in a manner consistent with our data retention guidelines.
Transferring data internationally
There are restrictions on international transfers of personal data. You must not transfer personal data anywhere outside the UK without first consulting the Data Protection Officer.
Subject access requests
Please note that under the Data Protection Act 1998, individuals are entitled, subject to certain exceptions, to request access to information held about them.
If a subject access request is received, it should be referred to ProAm Champions Ltd.
Please contact ProAm Champions Ltd if you would like to correct or request information that we hold about you. There are also restrictions on the information to which you are entitled under applicable law.
Processing data in accordance with the individual’s rights
You should abide by any request from an individual not to use their personal data for direct marketing purposes and notify ProAm Champions Ltd about any such request.
Do not send direct marketing material to someone electronically (e.g. via email) unless you have an existing business relationship with them in relation to the services being marketed.
Please contact ProAm Champions Ltd for advice on direct marketing before starting any new direct marketing activity.
What information is being collected?
Who is collecting it?
Our members, suppliers & employee’s data is collected as and when a new one arises.
Data used for mailing purposes are supplied by our clients to be processed according to the completed application of membership/work.
How is it collected?
Our member, supplier & employee’s data is collected at the initial stage when receiving membership applications. Information will be collected via email & post to satisfy the needs of our documentation.
Why is it being collected?
We are provided data by our members to process licenses and memberships. Third parties are informed of data if consent is given.
We collect information on our suppliers to conduct business and provide invoices.
Who will it be shared with?
Data may be shared with a third party supplier if it is deemed appropriate with member consent.
We also may share the data externally if exceptional circumstances apply or we are required to do this by law.
Justification for personal data
We will process personal data in compliance with all eight data protection principles:
We will document the additional justification for the processing of sensitive data, and will ensure any biometric and genetic data is considered sensitive.
The data that we collect is subject to active consent by the data subject. This consent can be revoked at any time. With reference to the data supplied by our members/customers to conduct a job, it is our customers responsibility as the data owners to gain active consent.
Criminal record checks
Any criminal record checks are justified by law. Criminal record checks cannot be undertaken based solely on the consent of the subject.
Upon request, a data subject should have the right to receive a copy of their data in a structured format. These requests should be processed within one month, provided there is no undue burden and it does not compromise the privacy of other individuals. A data subject may also request that their data is transferred directly to another system. This must be done for free.
Right to be forgotten
A data subject may request that any information held on them is deleted or removed, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies.
Privacy by design and default
Privacy by design is an approach to projects that promote privacy and data protection compliance from the start. ProAm Champions Ltd will be responsible for conducting Privacy Impact Assessments and ensuring that all IT projects commence with a privacy plan.
When relevant, and when it does not have a negative impact on the data subject, privacy settings will be set to the most private by default.
International data transfers
No data may be transferred outside of the EEA. Specific consent from the data subject must be obtained prior to transferring their data outside the EEA. This consent may be actioned by ProAm Champions Ltd
Data audit and register
Regular data audits to manage and mitigate risks will inform the data register. This contains information on what data is held, where it is stored, how it is used, who is responsible and any further regulations or retention timescales that may be relevant.
This allows us to:
Everyone must observe this policy. ProAm Champions Ltd has overall responsibility for this policy. They will monitor it regularly to make sure it is being adhered to.
Consequences of failing to comply
We take compliance with this policy very seriously. Failure to comply puts the organisation at risk.