Data Protection, Privacy & Cookies Policy
26 March 2020
means the Heights Hub, a volunteer-led community group, and their website www.heightshub.scot
means the General Data Protection Regulations.
means Jeremy Astill-Brown, on behalf of the Organisation.
Register of Systems
means a register of all systems or contexts in which personal data is processed by the Organisation.
1. Data protection principles
The Organisation 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 Organisation.
- The Responsible Person shall take responsibility for the Organisation’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
- The Organisation shall, if required, 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 Organisation 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 Organisation shall be dealt with in a timely manner.
4. Lawful purposes
- All data processed by the Organisation 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).
- The Organisation 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 Organisation’s systems.
5. Data minimisation
- The Organisation shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- The purposes for which they are processed shall be limited to the provision of help and support during the Covid-19/Coronavirus pandemic and for no other purpose.
- The Organisation 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, and unless otherwise required by law, the Organisation shall delete all personal data and information collected by it within 6 months of the pandemic having ended. If need be, this policy will be reviewed
- For any data or information that is required by law to be retained, an archiving policy shall be drafted and shall consider what data should/must be retained, for how long, and why.
- The Organisation 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.
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 Organisation 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
Personal data collected via this website and why we collect it
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Embedded content from other websites
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How long we retain your data
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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.