Data Protection Policy
- This policy has been prepared by Sandra McRitchie.
- This policy became operational on 16 Feb 2021.
- Next review date: 16 Feb 2022.
Comrie Community Council (the “organisation”) needs to gather and use certain information about individuals.
These can include customers, 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 company’s data protection standards — and to comply with the law.
Why this policy exists
This data protection policy ensures that the organisation:
- Complies with data protection law and follow good practice
- Protects the rights of customers and partners
- Is open about how it stores and processes individuals’ data
- Protects itself from the risks of a data breach
Data protection law
The GDPR describes how organisations — including the organisation — 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 GDPR is underpinned by eight important principles. These say that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
- Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
People, risks and responsibilities
This policy applies to:
- The head office of the organisation
- All branches of the organisation
- All staff and volunteers of the organisation
- All contractors, suppliers and other people working on behalf of the organisation
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:
- Names of individuals
- Postal addresses
- Email addresses
- Telephone numbers
- …plus any other information relating to individuals
Data protection risks
This policy helps to protect the organisation 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 company uses data relating to them.
- Reputational damage. For instance, the organisation could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with the organisation has some responsibility for ensuring data is collected, stored and handled appropriately. Whomever at the organisation 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:
Sandra McRitchie is ultimately responsible for ensuring that the organisation meets its legal obligations. Sandra McRitchie is responsible for:
- Keeping updated about data protection responsibilities, risks and issues.
- Reviewing all data protection procedures and related policies, in line with an agreed schedule.
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data the organisation holds about them (also called ‘subject access requests’).
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
Sandra McRitchie is responsible for IT used at the organisation, including computers, laptops, mobile phones and other devices that can store personal data. Sandra McRitchie will ensure
- that 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.
Sandra McRitchie is responsible for any marketing related activities at the organisation. She 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 staff to ensure marketing initiatives abide by data protection principles.
General guidelines for data usage
- The only people able to access data covered by this policy should be those who need it for their work.
- Data should not be shared informally. When access to confidential information is required, it can be request from Sandra McRitchie.
- The organisation will request that suppliers understand their responsibilities when handling data.
- 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 company 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.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller. When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see or access 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. Sandra McRitchie will 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 employees.
If data is stored on removable media (like a USB or external disk), 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 company’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.
Personal data is of no value to the organisation unless the organisation 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, Sandra McRitchie will 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.
- Personal data should never be transferred outside of the European Economic Area.
- Only central copies of any data will accessed and updates. There must not be multiple copies of personal data.
The law requires the organisation 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 organisation should put into ensuring its accuracy. Sandra McRitchie is 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. Sandra McRitchie should not create any unnecessary additional data sets. Sandra McRitchie should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call. The organisation will make it easy for data subjects to update the information the organisation holds about them. For instance, via the organisation’s website. Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database. It is the Sandra McRitchie’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
Subject access requests
All individuals who are the subject of personal data held by the organisation are entitled to:
- Ask what information the company 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 company is meeting its data protection obligations.
If an individual contacts the company requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, using the below contact form. Enquiries sent through this form are sent directly to Sandra McRitchie.
Individuals will not charged. Sandra McRitchie will aim to provide the relevant data within 30 days.
Sandra McRitchie will always verify the identity of anyone making a subject access request before handing over any information.
Disclosing data for other reasons
In certain circumstances, the GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, the organisation will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
The organisation 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 company has a privacy statement, setting out how data relating to individuals is used by the organisation.
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So what information does a cookie collect?
Cookies in general collect details about the pages you are looking at when you access a website via the same computer or device. This includes information about the pages you viewed, and the trail of pages you have looked at within one website.
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What I do with Google Analytics
I use Google Analytics software on my website to collect information about how you use my website. I do this to help make sure that my website site is meeting the needs of my existing and potentially new clients and it also helps me to make continuous improvements to my website.
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Can I disable cookies?
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Does anything happen when you disable cookies?
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When someone visits www.comrie.org.uk, I use a third party service, Google Analytics, to collect standard internet log information and details of my website visitors’ behaviour patterns. I do this to find out things such as the number of visitors to the various parts of my website. This information is only processed in a way which does not identify anyone. I do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
Access to your personal information
If you are a client, or have enquired about my services, I will keep some personal data on file. You are entitled to view, amend, or request the personal information that we hold to be deleted. Email your request to Sandra McRitchie, using the form above.
Your privacy is important to me and we have taken measures to make sure that we protect it and let you know how we will use it. Below, you will find how your information is used.
Submitting a form on my website
I will use the information that you provide to me on my website to provide you with information you request, or to provide the services that you have requested. This may involve e-mailing you to confirm the service and for other administrative matters or to inform you about changes to the service or to notify you of new services.
Use of this website
This Website is controlled and operated by the Comrie Community Council, Comrie, Scotland, United Kingdom (the organisation). The organisation makes no representation that materials in the website are appropriate or available for use in other locations. Anyone who elects to access this website from any other location does so on their own initiative and is responsible for compliance with applicable local laws.
Use of website
The terms and conditions apply to your use of the organisation’s website at www.comrie.org.uk (the “Website”). The terms and conditions apply regardless of how you access the website, including any devices by which you can access the website at home, or on the move. You must read these Terms and Conditions carefully, and we recommend that you print and keep a copy for your future reference. By accessing, browsing, using the Website or sending me information through the website, you confirm that you have read, understood and agree to these terms and conditions in their entirety. If you do not agree to these terms and conditions in their entirety, please do not use this website.
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Links to external websites
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