This document defines the term and sets out the principles, practices and procedures which Hellenic Community of Manchester will follow in order to protect all personal information collected from individuals.
Data Protection Policy
Context and overview
Policy prepared by: Iraklis Lampadariou
Policy became operational on: 15 July 2020
Next review date: 15 July 2021
Hellenic Community of Manchester (The Association or HCM) and its Steering Committee (SC – Συντονιστική Επιτροπή) needs to collect, handle and store certain data and information about its individual members for The Association’s smooth operation in full compliance with its internal Governing Policy (Καταστατικό)
This HCM Data Protection Policy (The Policy) describes how personal data will be collected, handled and stored by the five members of the SC to meet the data protection requirements of Hellenic Community of Manchester – and to fully comply with Data Protection Act 2018 and any applicable legislation.
Why this policy exists
This HCM Data Protection Policy ensures Hellenic Community of Manchester and the five members of its Steering Committee have the responsibility to:
- Process any personal data in line with data protection principles
- Protect the rights of anyone (member or non-member) who contacts the Unincorporated Association
- Assist anyone (member or non-member) in exercising their data protection rights in the context of The Association’s environment
- Protect The Association from data protection breaches. In the case of a data breach, the appointed controller of the Steering Committee shall without undue delay and, where feasible, notify the relevant supervisory authority, not later than 72 hours after having become aware of it.
Data protection law
The UK Data Protection Act 2018 (DPA 2018)
(https://www.legislation.gov.uk/ukpga/2018/12/contents/enacted/data.htm) which incorporates the EU General Data Protection Regulation (GDPR) (https://www.gov.uk/government/publications/guide-to-the-general-data-protection-regulation) describes how organisations – including Hellenic Community of Manchester – should collect, handle and store personal data and information.
Hellenic Community of Manchester is registered as a Data Controller at the Information Commissioner’s Office (www.ico.gov.uk).
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 Data Protection Act is underpinned by eight important principles. These say that personal data must:
- 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
The DPA 2018 supplements the EU General Data Protection Regulation (GDPR), which came into effect on 25 May 2018. The GDPR regulates the collection, storage, and use of personal data significantly more strictly. Significant and wide-reaching in scope, the new law brings a 21st century approach to data protection. It expands the rights of individuals to control how their personal information is collected and processed, and places a range of new obligations on organisations to be more accountable for data protection. The Association has taken a risk-based approach to data protection, ensuring appropriate policies and procedures are in place to deal with the transparency, accountability and individuals’ rights provisions in order to comply with the law.
People, risks and responsibilities
The Policy applies to:
- Hellenic Community of Manchester (as an Unincorporated Association)
It applies to all data that Hellenic Community of Manchester holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 2018. This can include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- Any documents to prove citizenship and postal address
- names or other identifiers of online accounts such as Skype names, Facebook profiles, Twitter accounts, Instagram accounts etc.
Hellenic Community of Manchester will never ask for the following special categories of personal data from individuals:
- Political opinions
- Trade union membership
- Sexual orientation
- Health information
- Biometric data
- Genetic data
Data protection risks
The Policy helps to protect Hellenic Community of Manchester from some very real data security risks including:
- Breaches of privacy and confidentiality. For instance, information being given out inappropriately.
- Failing to offer choice. For instance, all individuals should be free to choose how Hellenic Community of Manchester used data relating to them.
- Reputational damage. For instance, Hellenic Community of Manchester could suffer if hackers successfully gained access to sensitive data.
The members of the SC of HCM and Mr Iraklis Lampadariou, appointed as the Data Protection Officer, has full responsibility for ensuring data is collected, stored and handled appropriately in line with The Policy and applicable data protection principles.
These rules describe how and where data should be safely stored.
The Hellenic Community of Manchester follows an environmentally friendly approach. This means that data related with personal information is not stored on paper.
All the data related with personal information is stored electronically only and it will never been printed out. The data is protected from unauthorised access, accidental deletion and malicious hacking attempts:
- Data is never stored on removable media (like a CD, DVD or USB flash drive).
- Data is stored on a laptop and a smart phone, both with passwords, updated antivirus software and a firewall.
Individuals should give their consent by agreeing to the ‘Consent form’ which is available on the website https://hellenicmanchester.co.uk/under the Contact/Privacy section.
- ‘Consent form’ is intelligible and in clear, plain language.
- ‘Consent form’ does not have any pre-ticked boxes or any other details which might require a silent consent from the individuals.
- Consent can be withdrawn at any time by sending an email to email@example.com
Personal data is used:
- to contact the individuals via communication means (e.g. e-mail, text, social media) of the activities of the association and news related to its mission, purpose and operations.
- to prove the individuals can be members of Hellenic Community of Manchester according to its Constitution (Καταστατικό – https://hellenicmanchester.co.uk/katastatiko/)
The law requires Hellenic Community of Manchester to take reasonable steps to ensure data is kept accurate and up to date.
It is the responsibility of Mr Iraklis Lampadariou to take reasonable steps to ensure it is kept as accurate and up to date as possible.
- Data will be held only on a laptop and a smart phone.
- Data is stored only as long as is necessary.
- Hellenic Community of Manchester should take every opportunity to ensure data is updated. For instance, by confirming a member’s details when they call.
- Hellenic Community of Manchester will make it is easy for data subjects to update the information Hellenic Community of Manchester holds about them. For instance, via the email firstname.lastname@example.org
- 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.
Subject Access Requests (SARs)
All individuals who are the subject of personal data held by Hellenic Community of Manchester are entitled to:
- Ask what information the Unincorporated Association 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 Unincorporated Association is meeting its data protection obligations.
If an individual contacts The Association requesting this information, this is called a subject access request. Subject access requests from individuals should be made by email, addressed to the HCM data controller, Mr Iraklis Lampadariou, at email@example.com
There is no charge for the individuals for their subject access request. The data controller will aim to provide the relevant data within 48 hours.
The data controller will always verify the identity of anyone making a subject access request before handling over any information.
Disclosing data for other reasons
In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Hellenic Community of Manchester will disclose requested data. However, the data controller will still ensure the request is legitimate.
Hellenic Community of Manchester 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
If you have any enquiries in relation to The Policy, please contact Mr Iraklis Lampadariou, a member of the SC of The Association, who will also act as the contact point for any Subject Access Requests.
Further advice and information on data protection is available from the Information Commissioner’s Office (www.ico.org.uk).
(End of this policy document)