Data Protection Policy

1 Context and Overview

1.1 Key Details

  • Policy prepared by: Gareth Wear
  • Approved by Management Committee: 26th April 2018
  • Policy Became operational on: 26th April 2018
  • Next review date: 1st May 2020

1.2 Introduction

Invicta Military-Vehicle Preservation Society needs to gather and use certain information about individuals.

These can include members, guests, volunteers, suppliers, business contacts and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the Club’s data protection standards — and to comply with the law.

1.3 Why This Policy Exists

This data protection policy ensures Invicta Military-Vehicle Preservation Society:

  • Complies with data protection law and follows good practice
  • Protects the rights of volunteers, members and partners
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risks of a data breach

1.4 General Data Protection Regulation (GDPR) 2018

The General Data Protection Regulation 2018 describes how organisations — including Invicta Military-Vehicle Preservation Society – must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The General Data Protection Regulations 2018 is underpinned by eight important principles. These say that personal data must:

  1. Be processed fairly and lawfully
  2. Be obtained only for specific, lawful purposes
  3. Be adequate, relevant and not excessive
  4. Be accurate and kept up to date
  5. Not be held for any longer than necessary
  6. Processed in accordance with the rights of data subjects
  7. Be protected in appropriate ways
  8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

2 People, Risks and Responsibilities

2.1 Policy Scope

This policy applies to:

  • The registered address of Invicta Military-Vehicle Preservation Society
  • All homes and remote locations of volunteers of Invicta Military-Vehicle Preservation Society
  • All members and volunteers of Invicta Military-Vehicle Preservation Society
  • All contractors, suppliers and other people working on behalf of Invicta Military-Vehicle Preservation Society

It applies to all data that the Club holds relating to identifiable individuals, even if that information technically falls outside of the General Data Protection Regulations 2018. This can include:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • …plus any other information relating to individuals

2.2 Data Protection Risks

This policy helps to protect the Invicta Military-Vehicle Preservation Society from some very real data security risks, including:

  • Breaches of confidentiality. For instance, information being given out inappropriately.
  • Failing to offer choice. For instance, all individuals should be free to choose how the Club uses data relating to them.
  • Reputational damage. For instance, the Club could suffer if hackers successfully gained access to sensitive data.

2.3 Responsibilities

Everyone who works/volunteers for or with the Invicta Military-Vehicle Preservation Society has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

  • The Management Committee is ultimately responsible for ensuring that the Invicta Military-Vehicle Preservation Society meets its legal obligations.
  • The Data Protection Officer, Gareth Wear, is responsible for:
  • Keeping the Management Committee updated about data protection responsibilities, risks and issues.
  • Reviewing all data protection procedures and related policies annually.
  • Arranging data protection training and advice for the people covered by this policy.
  • Handling data protection questions from members and anyone else covered by this policy.
  • Dealing with requests from individuals to see the data the Invicta Military-Vehicle Preservation Society holds about them (also called ‘subject access requests’).
  • Checking and approving any contracts or agreements with third parties that may handle the Club’s sensitive data.
  • The Webmaster/IT Officer, Gareth Wear, is responsible for:
  • Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
  • Performing regular checks and scans to ensure security hardware and software is functioning properly.
  • Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
  • The Chairman, Nick Cowles is responsible for:
  • Approving any data protection statements attached to communications such as emails and letters.
  • Addressing any data protection queries from journalists or media outlets like newspapers.
  • Where necessary, working with other members to ensure marketing initiatives abide by data protection principles.

3 General Volunteer and Member Guidelines

  • The only people able to access data covered by this policy should be those who need it for their work within the Invicta Military-Vehicle Preservation Society.
  • Data should not be shared informally. When access to confidential information is required, volunteers and members can request it from the management committee.
  • The Invicta Military-Vehicle Preservation Society will provide training where appropriate to all volunteers and members to help them understand their responsibilities when handling data.
  • Volunteers and members should keep all data secure, by taking sensible precautions and following the guidelines below.
  • In particular, strong passwords must be used and they should never be shared.
  • Personal data should not be disclosed to unauthorised people, either within the organisation or externally.
  • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
  • Volunteers and members should request help from the Management Committee or the data protection officer if they are unsure about any aspect of data protection.
  • Credit Card, Debit Card and bank account details are only retained by our authorised and regulated banking partners on their secure servers.
  • Credit Card, Debit Card and bank account details are never kept on paper or on our server. Paper copies should be shredded once processed.

4 Data

4.1 Data Storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Webmaster/IT manager.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

  • When not required, the paper or files should be kept in a locked drawer or filing cabinet.
  • Volunteers and members should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
  • Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords that are changed regularly and never shared between members who are not part of the Management Committee or IT support.
  • If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
  • Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
  • Servers containing personal data should be sited in a secure location, away from general office space.
  • Data should be backed up frequently. Those backups should be tested regularly, in line with the organisation’s standard backup procedures.
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
  • All servers and computers containing data should be protected by approved security software and a firewall.

4.2 Data Use

Personal data is of no value to the Invicta Military-Vehicle Preservation Society unless the Club can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

  • When working with personal data, those who have legitimate access to it should ensure the screens of their computers are always locked when left unattended.
  • Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
  • Data must be encrypted before being transferred electronically. The Webmaster/IT manager can explain how to send data to authorised external contacts.
  • Personal data should never be transferred outside of the European Economic Area.
  • Volunteers and members wherever possible should not save copies of personal data to their own computers. Always access and update the central copy of any data.

4.3 Data Accuracy

The law requires the Invicta Military-Vehicle Preservation Society to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort The Invicta Military-Vehicle Preservation Society should put into ensuring its accuracy.

It is the responsibility of all volunteers and members who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

  • Data will be held in as few places as necessary. Volunteers and members should not create any unnecessary additional data sets.
  • Volunteers and members should take every opportunity to ensure data is updated. For instance, by confirming a member’s details when they call.
  • The Invicta Military-Vehicle Preservation Society will make it easy for data subjects to update the information the Invicta Military-Vehicle Preservation Society holds about them. For instance, via the Club website.
  • Data should be updated as inaccuracies are discovered. For instance, if a member can no longer be reached on their stored telephone number, it should be removed from the database.

4.4 Subject Access Requests

All individuals who are the subject of personal data held by the Invicta Military-Vehicle Preservation Society are entitled to:

  • Ask what information the organisation holds about them and why.
  • Ask how to gain access to it.
  • Be informed how to keep it up to date.
  • Be informed how the Club is meeting its data protection obligations.

If an individual contacts the Club requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller at webmaster@imps.org.uk

Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

4.5 Disclosing Data for Other Reasons

In certain circumstances, the General Data Protection Regulation 2018 allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, the Invicta Military-Vehicle Preservation Society will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the Management Committee and from the Club’s legal advisers where necessary.

4.6 Providing Information

The Invicta Military-Vehicle Preservation Society aims to ensure that individuals are aware that their data is being processed, and that they understand:

  • How the data is being used
  • How to exercise their rights

To these ends, the Society has a privacy statement contained within its bylaws and rules which is available on the Society’s website.