Data Protection Policy
This data protection policy explains how we store confidential information.
For information on what data we hold and who we hold it on, please see our Privacy Notice on our website.
Information is stored on our Google Drive and Microsoft OneDrive accounts, as well as occasionally on paper in locked storage in our office. Information may be printed out and shared within our organization to facilitate delivery of the service we provide and will be destroyed once the service has been provided.
The Besom in York does not have its own network; electronic data is held securely on Google drive and Microsoft OneDrive.
Users should take measures to ensure that paper notebooks or items of electronic equipment holding personal data are reasonably secure. If such devices are portable then extra care is required to prevent theft and to secure sensitive data stored on the device. When paper copies containing personal data exist they will be securely stored in locked filing cabinets in locked rooms. Paper copies of files, e.g. delivery schedules, should be returned to the office for secure storage or securely disposed at the end of an activity. Where documents must be printed to facilitate activities, they should contain the minimum of data necessary for the completion of the activity.
Sensitive data should only be released to trusted users who have read this policy and have been trained in how to secure data. Users must appreciate the potential risks to clients and the organisation. Users should think carefully about what information to release to other volunteers and only release that which is necessary for the completion of a given activity.
Data files or folders containing sensitive personal data must be secured with a strong password. Computers or other electronic devices holding such data should themselves require a secure logon with a suitably strong password or security lock. Try to avoid writing down passwords but if written down they should be kept securely, ideally locked away, and in a location separate from any device that may be accessed using such passwords.
Email & Internet Use
Sharing of personal data over the internet or via email should only take place between trusted users within the organisation. Where files are shared on email or via internet file storage then all such files should be protected with a strong password. Where password protected files are shared by email, the password for the file should never be sent in the same email. Personal data should not be sent openly by email. BCC should be used when sending group emails to protect privacy of email addresses. For the purpose of keeping statistical records or sharing activities inside or outside of the organisation in the form of – e.g. blogs, newsletters or reports to the Charity Commission – all personal data must be anonymized. Anonymization should not only change names but also not give sufficient information to identify any individual.
Data Storage and Maintenance
Management of Breaches
Any breach or potential breach of security should be reported to the trustees. In the result of a serious breach which could result in sensitive data regarding a vulnerable individual being made available to someone who could misuse this to cause harm, e.g. a person seeking a vulnerable person in a refuge, the Care Professional responsible for the vulnerable person’s care must be contacted to advise them of the breach. Take measures to contain the breach, e.g. change passwords, and review security arrangements. Loss of data that is securely protected (e.g. theft of a securely encrypted laptop) does not represent a serious breach. The trustees will review all data breaches and change policies as appropriate. All data breaches should be reported upward through the national Besom organisation so that policies and actions can be reviewed and lessons learnt at local and national level. Where appropriate, breaches will be reported to the ICO (Information Commissioner’s Office) and individuals whose personal data is involved will be notified.
Trusted data users should be trained in data protection before given access to sensitive data in electronic forms. Volunteers involved in delivering goods and services should be informed and regularly reminded of the importance on maintaining data security and the importance of returning scheduling forms back to data managers especially where vulnerable clients are involved. Trustees should encourage a security aware culture amongst volunteers.
The Besom in Sheffield operates under the lawful basis of “Legitimate Interests” with respect to the processing of client (recipient) and donor data (givers). The Legitimate Interest is we require certain data, e.g. contact data and address data, in order to deliver the services we offer both to clients and donors.
The Besom in Sheffield operates under the lawful basis of “Consent” with respect to the processing of volunteer (time givers) data. Volunteers will be required to fill in a form giving consent to hold key information including contact data, emergency contact details, references, and in the case of those volunteering to drive the van, a copy of their driving licence.
What information do we collect about you?
Recipients (clients) and Referring Agencies – When referred or referring we will collect the minimum of information to meet the need you have been referred for or are referring. When we are able to meet all or part of that need we will request full information to allow us to do so, usually address and phone number so that we can contact you to arrange delivery of items.
Donors – When you contact us about giving we collect the minimum of information necessary to deal with your donation usually phone number or email and address. In the case of a gift aided financial donation we will collect your name and address. In the event we cannot process your donation immediately we will store your phone number or email for you and when we are able to process your donation will contact you to request further information, usually your address so that we can collect items.
Volunteers (time givers) – When you volunteer you will be asked to fill in a form with your contact details, reference details and details of an emergency contact. Volunteers willing to drive the van will also have a photocopy of their driving licence taken. We will take up a reference from the individual you provide, this will include information about your religious beliefs and any other information the referee feels is applicable to your volunteering role, including your suitability to work with vulnerable adult and children.
How will we use the information about you?
Recipients and Referring Agencies – we will initially use the information we collect from you to contact you to discuss the delivery of services to you or your clients. We will then use your information to provide you with any service(s) we have agreed with you and keep referring agencies updated with progress.
Donors – we will use the information we collect from you to process your donation and to thank you for your support.
Volunteers – we will use the information we collect from you to contact you about your volunteering, as well as to invite you to events such as prayer meetings and conferences.
Sharing your information
We will not share any personal information we hold about you with anyone outside our organization without your prior consent. We may share stories of our work, but whenever doing so we will ensure that you are not identifiable.
Retaining and deleting your information
We will take all reasonable steps to ensure that the information we hold about you is kept secure. We will only hold your personal data for as long as it is required. Deleting your information may involve either the removal of the data or its anonymization, meaning that it no longer continues to be personal data that will identify you. Please contact us using the details below if you wish to request that your data be deleted.
Access to your information and correction
You have the right to request details of the information we hold about you. To do this, you should send an email to the address below. We will respond to your request within 30 days of receiving the written request. You have the right to request that we update, correct or delete any information we hold about you. Please contact us using the details below to let us know what needs changing.
How to contact us
By phone: 07875950170
For more information about your legal rights in relation to the information we hold about you, please visit the Information Commissioner’s Office at ico.org.uk