Data Handling Policy

Data Handling Policy

Definition

Organisation means [Yachad], a combined entity of a registered Charity and a Limited Company
Data Subject means [The individual for whom the identifying data belongs].
Responsible Person means [Ross McGregor].
Databases means [Salesforce & Engaging Networks], the CRM database systems in use by Yachad.
Deletion means removing all data.
Anonymisation means rendering data anonymous, in such a way that the data subject is not or no longer identifiable.

 

Deletion & Anonymisation Criteria

The Organisation endeavours to delete any data subject’s personal information when the following criteria are met:

  1. The data subject has opted out of receiving updates, marketing and campaign communications from the Organisation;
  2. There has been no activity, donations or participation since the data subject provided their information;
  3. The data subject has not opened an email in the last 12 months; and
  4. A period of three (3) years has passed, since the data subject provided their information, OR, the data subject has requested the removal of their information.

Alternatively, for the purposes of historical accounting, accurate participation numbers and overall engagement, the Organisation will anonymise the data when the following criteria have been met:

  1. The data subject has opted out of receiving updates, marketing and campaign communications from the Organisation;
  2. The data subject has donated, participated in a campaign or been in touch with the Organisation, since providing their information;
  3. The data subject has not opened an email in the last 12 months; and
  4.  period of three (3) years has passed, since the data subjects last interaction with the Organisation, OR, the data subject has requested the removal of their information

Deletion & Anonymisation Identification Processes:

The Organisation will identity which data requires removal or anonymisation, via the following processes:

  1. If the data subject has communicated to the Organisation that they wish for their data to be removed, as there are entitled to under Article 17 GDPR – Right to erasure (‘right to be forgotten’); and
  2. Once a month, the Organisation will run a report, via both Databases, and produce a list of data subjects who match the above ‘Deletion’ or ‘Anonymisation’ criteria. This will then be manually checked and deletion or anonymisation carried out.

Anonymisation Exceptions

The Organisation will retain the following information, in order to comply with UK funding source identification rules or due to legitimate interest:

  1. The first and last name of previous donors; and
  2. The postal address of previous donors (unless the data subject has requested its deletion).

Data Collection

The collection of personal data, whether via the Organisation’s website, a handwritten sign up sheet or any other method, will clearly comply with the requirements of Article 13 of the GDPR, which states:

  • Where personal data relating to a data subject are collected from the data subject, the controller shall, at the time when personal data are obtained, provide the data subject with all of the following information:
    1. the identity and the contact details of the controller and, where applicable, of the controller’s representative;
    2. the contact details of the data protection officer, where applicable;
    3. the purposes of the processing for which the personal data are intended as well as the legal basis for the processing;
    4. where the processing is based on point (f) of Article 6, the legitimate interests pursued by the controller or by a third party;
    5. the recipients or categories of recipients of the personal data, if any;
    6. where applicable, the fact that the controller intends to transfer personal data to a third country or international organisation and the existence or absence of an adequacy decision by the Commission, or in the case of transfers referred to in Article 46or 47, or the second subparagraph of Article 49, reference to the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available.
  • In addition to the information referred to in paragraph 1, the controller shall, at the time when personal data are obtained, provide the data subject with the following further information necessary to ensure fair and transparent processing:
    1. the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
    2. the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability;
    3. where the processing is based on point (a) of Article 6 or point (a) of Article 9(2), the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
    4. the right to lodge a complaint with a supervisory authority;
    5. whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data;
    6. the existence of automated decision-making, including profiling, referred to in Article 22, and at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
  • Where the controller intends to further process the personal data for a purpose other than that for which the personal data were collected, the controller shall provide the data subject prior to that further processing with information on that other purpose and with any relevant further information as referred to in paragraph 2.
  • Paragraphs 1, 2 and 3 shall not apply where and insofar as the data subject already has the information.

All collection points, both digital and physical, will comply with Article 13, with a scanned copy of any physical sign up sheets retained as evidence of consent and Data source.

Identification of consenting and relevant Data Subjects:

Before producing any mass communications, whether campaigning, advertising, educational or other in nature, the Organisation will identify the Data Subjects who have opted in to receiving communications and who have not opted out of mass communications. The Organisation will then save a record of this list in a secure location, for future reference and/or evidence.

The record will include the following information:

  1. Campaign Name;
  2. Purpose (advocacy\fundraising\newsletter);
  3. Recipients (why are we sending this email to this group of people); and
  4. Date.

Data Subject Communication Preferences:

The Organisation will comply with the wishes of the Data Subject’s, when they withdraw their consent to be contacted, withdraw consent to receive mass communications or withdraw consent to telephone communications.

The Organisation will record Data Subject’s preference, offering the options of:

  1. General opt-in: where the Data Subject agrees to all relevant communications;
  2. No telephone calls: where the Data Subject consent to all relevant non-telephone communications;
  3. Mass communication opt-out: where the Data Subject has opted out of mass/generic email communications, but has consented to individual contacts; and
  4. General opt-out: where the Data Subject has opted out of all communications.

These preferences will be recorded on the Organisation’s Databases, with explanatory notes added to any manual (employee created) changes.

The Organisation will also review and, if necessary, revise this policy, on an annual basis.

END OF POLICY