St Dominick Community Shop CBS Ltd
Created August 2020
GDPR: General Data Protection Regulation.
Responsible Person: The Company Secretary
CBS: Community Benefit Society, legal structure registered with the Financial Conduct Authority
- Data protection principles
St Dominick Community Shop is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
- General provisions
a. This policy applies to all personal data processed by the CBS.
b. The Responsible Person shall take responsibility for the CBS’s ongoing compliance with this policy.
c. This policy shall be reviewed at least annually.
- Lawful, fair and transparent processing
a. To ensure its processing of data is lawful, fair and transparent, the CBS shall maintain a Register of Systems.
b. The Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and any such requests made to the CBS shall be dealt with in a timely manner.
- Lawful purposes
a. The legal basis for collecting personal information is the legitimate interest of running the organisation.
b. The CBS shall note the appropriate lawful basis in the Register of Systems.
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
d. 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 CBS’s systems.
e. When logging onto www.stominickcommunityshop.co.uk the web browser does not collect personal information. The CBS has access to statistical data only which does not allow identification of the user.
- Data minimisation
a. The CBS shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
a. The CBS shall take reasonable steps to ensure personal data is accurate.
b. 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.
- Archiving / removal
a. To ensure that personal data is kept for no longer than necessary, the CBS shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
b. The archiving policy shall consider what data should/must be retained, for how long, and why.
a. The CBS shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
b. 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.
c. When personal data is deleted this should be done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.
Privacy & Data Collection Policy
St Dominick Community Shop CBS Ltd
Register of Systems
The legal basis for collecting personal information is the legitimate interest of running the organisation.
- The purpose for collection of data is the smooth and legitimate running of the organisation and the communication with shareholder members.
- Personal Data will be stored in password protected file saved in Dropbox. All directors have access to Dropbox but the password for personal data files will be known only by Company Secretary and Treasurer.
- The Responsible Person will carry out an annual check of personal data held to ensure it is compatible with the current register of members. The responsible person shall report to the board of directors during March of each year that the CBS is compliant with this policy.
- Data that is archived will be kept in an archive file save to the Dropbox and password protected known only to Company Secretary and Treasurer.