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Data Protection Policy

Data Protection Policy, including Key Procedures

Name of organisation: Baggage Reclaim School

Aims of this Policy

Baggage Reclaim School needs to keep certain information on its students to carry out its day to day operations, to meet its objectives and to comply with legal obligations.The organisation is committed to ensuring any personal data will be dealt with in line with the Data Protection Act 1998. To comply with the law, personal information will be collected and used fairly, stored safely and not disclosed to any other person unlawfully. 

The aim of this policy is to ensure that everyone handling personal data is fully aware of the requirements and acts in accordance with data protection procedures. This document also highlights key data protection procedures within the organisation.

This policy covers students who are enrolled on the private membership online school.

 

Definitions

In line with the Data Protection Act 1998 principles, Baggage Reclaim School will ensure that personal data will:

  • Be obtained fairly and lawfully and shall not be processed unless certain conditions are met
  • Be obtained for a specific and lawful purpose
  • Be adequate, relevant but not excessive
  • Be accurate and kept up to date
  • Not be held longer than necessary
  • Be processed in accordance with the rights of data subjects
  • Be subject to appropriate security measures
  • Not to be transferred outside the European Economic Area (EEA)

The definition of ‘Processing’ is obtaining, using, holding, amending, disclosing, destroying and deleting personal data. This includes some paper based personal data as well as that kept on computer.

The Personal Data Guardianship Code suggests five key principles of good data governance on which best practice is based. The organisation will seek to abide by this code in relation to all the personal data it processes, i.e.

Accountability: those handling personal data follow publicised data principles to help gain public trust and safeguard personal data.

Visibility: Data subjects should have access to the information about themselves that an organisation holds. This includes the right to have incorrect personal data corrected and to know who has had access to this data.

Consent: The collection and use of personal data must be fair and lawful and in accordance with the DPA’s eight data protection principles. Personal data should only be used for the purposes agreed by the data subject. If personal data is to be shared with a third party or used for another purpose, the data subject’s consent should be explicitly obtained.

Access: Everyone should have the right to know the roles and groups of people within an organisation who have access to their personal data and who has used this data.

Stewardship: Those collecting personal data have a duty of care to protect this data throughout the data life span.

 

Type of information processed

Baggage Reclaim School processes the following personal information. Personal information is kept in the following forms:

  • Your registration / enrollment / purchase form 
  • Member contact details.
  • Backstory – an overview of the background to what has led to you taking your course
  • Homework submitted although you might not be identifiable in it.
  • User details – login, display name (this is largely controlled by you)

Personal information is kept on a computer based system and is stored securely. Unless otherwise stated or requested by the user, data stored is removed and permanently deleted within 180 days of the end of the course.

Groups of people within the organisation who will process personal information are: Natalie Lue (owner and course instructor), Claire Archbold (School Manager) and Julie Carnell (Personal Assistant).

Responsibilities

Under the Data Protection Guardianship Code, overall responsibility for personal data rests with the owner. In the case of Baggage Reclaim School this is the Natalie Lue. All staff who process personal information must ensure they not only understand but also act in line with this policy and the data protection principles.

Breach of this policy will result in disciplinary/termination.

 

Policy Implementation

To meet our responsibilities staff will:

  • Ensure any personal data is collected in a fair and lawful way;
  • Explain why it is needed at the start;
  • Ensure that only the minimum amount of information needed is collected and used;
  • Ensure the information used is up to date and accurate;
  • Review the length of time information is held;
  • Ensure it is kept safely;
  • Ensure the rights people have in relation to their personal data can be exercised

We will ensure that:

  • Everyone managing and handling personal information is trained to do so.
  • Anyone wanting to make enquiries about handling personal information, whether a member of staff, volunteer or service user, knows what to do;
  • Any disclosure of personal data will be in line with our procedures.
  • Queries about handling personal information will be dealt with swiftly and politely.

 

Training

Training and awareness raising about the Data Protection Act and how it is followed in this organisation will take the following forms:

On induction:

  • A confidentially agreement is signed including non-disclosure.

General training/ awareness raising:

  • Receipt of enrolment forms (if applicable) and backstory/homework is signed for as proof of receipt and understanding.
  • Confidential notices go out on replies.

We actively review the way that information is shared by students to ensure that students don’t disclose private information about others or over-share.

 

Gathering and checking information

Before personal information is collected, we will consider:

  • why the information is being gathered
  • what the information will be used for

We will take the following measures to ensure that personal information kept is accurate:

  • reminders are sent regarding checking information, updating login details and changing passwords and about not sharing information disclosed in discussions
  • we only collect information that is absolutely pivotal to you accessing the course or additional content/resources (such as the Facebook group).
  • third parties don’t have access to this information

Personal sensitive information will not be used apart from the exact purpose for which permission was given.

Data Security

The organisation will take steps to ensure that personal data is kept secure at all times against unauthorised or unlawful loss or disclosure. The following measures will be taken:Password protection on personal information files

Restricted access

Personal data is not to be taken off site

Backup into secure, password protected cloud storage

Password protected attachments for sensitive personal information sent by email

Any unauthorised disclosure of personal data to a third party by an employee may result in termination.

Subject Access Requests

Anyone whose personal information we process has the right to know:

  • What information we hold and process on them
  • How to gain access to this information
  • How to keep it up to date
  • What we are doing to comply with the Act.

They also have the right to prevent processing of their personal data in some circumstances and the right to correct, rectify, block or erase information regarded as wrong.

Individuals have a right under the Act to access certain personal data being kept about them on computer and certain files. Any person wishing to exercise this right should apply in writing to (insert name of person within the organisation or title and contact details).

We may make a charge of £15 on each occasion access is requested.

The following information will be required before access is granted:

  • Full name and contact details of the person making the request, their relationship with Baggage Reclaim School, timescales etc.

Queries about handling personal information will be dealt with swiftly and politely.

We will aim to comply with requests for access to personal information as soon as possible, but will ensure it is provided within the 40 days required by the Act from receiving the written request and the access fee as listed above.

Review

This policy will be reviewed at intervals of 1 year to ensure it remains up to date and compliant with the law.

The following information will be required before access is granted:

Full name and contact details of the person making the request, their relationship with Baggage Reclaim School, timescales etc.

Queries about handling personal information will be dealt with swiftly and politely.

We will aim to comply with requests for access to personal information as soon as possible, but will ensure it is provided within the 40 days required by the Act from receiving the written request and the access fee as listed above.

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