The Powell Family Foundation

Data Protection Policy

1. Data protection principles
    
   1.1 The Powell Family Foundation (TPFF) is defined as a Data Controller under the UK General Data Protection Regulations (GDPR). This means TPFF “determine the purposes and means of the processing of personal data”. Data Controllers make decisions about processing activities. They exercise overall control of the personal data being processed and are ultimately in charge of and responsible for the processing.

   1.2 TPFF is committed to processing data in accordance with its responsibilities under UK GDPR and the Data Protection Act (2018) and Privacy and Electronic Communications Regulations (2019).

   1.3 UK 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 is permitted;
   • 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
    
   2.1 This policy applies to all personal data processed by TPFF.

   2.2 The Executive Director is designated as the Responsible Person who shall take responsibility for TPFF’s ongoing compliance with this policy.

   2.3 This policy shall be reviewed at least annually.

   2.4 As a ‘not for profit’ organisation TPFF is exempt from registration with the Information Commissioner’s Office (ICO).

 

3. Lawful, fair and transparent processing
    
   3.1 To ensure its processing of data is lawful, fair and transparent, TPFF shall maintain a register of all systems or contexts in which personal data is processed.

   3.2 This Data Register shall be reviewed at least annually.

   3.3 Individuals have the right to access their personal data and any such requests made to TPFF shall be dealt with in a timely manner.

   3.4 If any third parties, such as partner charities, process any data on behalf of TPFF or receive referral data, they will be asked to confirm that they have appropriate data protection policies and procedures in place.

 

4. Lawful purposes
    
   4.1 All data processed by TPFF 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).

   4.2 TPFF shall undertake a Legitimate Interest Assessment. This will be recorded and reviewed annually.

   4.3 TPFF shall note the appropriate lawful basis in the Data Register but undertakes no activities which require the collection, holding and/or processing of personal information for reasons of vital interests or public tasks.

   4.4 Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.

   4.5 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 TPFF’s systems.

 

5. Data minimisation
    
   5.1 TPFF shall ensure that all personal data collected is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

   5.2 TPFF understand the types of processing that require a Data Protection Impact Assessment (DPIA) and the Responsible Person will use the screening checklist to identify whether or not a DPIA is necessary.

   5.3 TPFF does not use any automated decision making based on the data gathered.

 

6. Accuracy
    
   6.1 TPFF shall take reasonable steps to ensure personal data is accurate.

   6.2 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.

   6.3 In order to manage personal data in a secure and controlled environment all data is stored on SharePoint.

 

7. Archiving / removal
    
   7.1 To ensure that personal data is kept for no longer than necessary, TPFF shall consider what data should/must be retained, for how long, and why and this will be recorded by the Responsible Person on the Data Register.

 

8. Security
    
   8.1 TPFF shall ensure that personal data is stored securely using modern software that is kept up-to-date. This will include appropriate end-point security, password protection for the laptops, emails, relevant filing systems and social media accounts along with anti-virus protection.

   8.2 Access to personal data shall be limited to personnel who need access and appropriate security is in place to avoid unauthorised sharing of information.

   8.3 When personal data is deleted, this shall be done safely such that the data is irrecoverable.

   8.4 Appropriate back-up and disaster recovery solutions shall be in place via a Cloud based provider managed by QlicIT our IT service provider.

 

9. Breach
    
   9.1 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, TPFF 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).

   9.2 All breaches will be reported to the Board as and when they occur.

 

10. Responsibilities
     
    10.1 All staff, trustees, contractors and volunteers are expected to abide by this policy.

    10.2 The Executive Director will ensure compliance with the policy and report on this to the Board twice yearly.

    10.3 This policy will be reviewed annually.