PRIVACY

1. Data Protection Principles

The Friends of Corinium Museum is committed to processing data in accordance with its responsibilities under the Data Protection Act 2018.

2. General Provisions

This policy applies to all personal data processed by the Friends of Corinium Museum.

The Responsible Person is responsible for the Friends of Corinium Museum’s ongoing compliance with this policy. The Responsible Person is a member of the Friends of Corinium Museum committee.

The policy shall be reviewed at least annually.

The Friends of Corinium Museum shall register with the Information Commissioner’s Office as an organisation that processes personal data.

3. Lawful, fair and transparent processing

To ensure its processing of data is lawful, fair and transparent, the Friends of Corinium Museum maintains a Register of Systems.

The Register of Systems is reviewed at least annually

Individuals have the right to access their personal data and any such requests made to the Friends of Corinium Museum will be dealt with in a timely manner.

4. Lawful purposes

All data processed by the Friends of Corinium Museum must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.

The Friends of Corinium Museum shall note the appropriate lawful basis in the Register of Systems.

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

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 the Friends of Corinium Museum’s systems.

5. Data minimisation

The Friends of Corinium Museum shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

6. Accuracy

The Friends of Corinium Museum shall take reasonable steps to ensure personal data is accurate.

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.

7. Archiving / removal

To ensure that personal data is kept for no longer than necessary, the Friends of Corinium Museum shall put in place an archiving policy for each area in which personal data is processed and review this process annually.

The archiving policy shall consider what data should/must be retained, for how long, and why.

8. Security

The Friends of Corinium Museum shall ensure that personal data is stored securely using modern software that is kept-up-to-date.

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

When personal data is deleted this should be done safely such that the data is irrecoverable.

Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach

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, the Friends of Corinium Museum shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO.

1st November 2022

Acknowledgement

The Friends of Corinium Data Protection Policy has been developed using a template freely available from White Fuse.