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Privacy & Data Protection Policy

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1. Introduction

Hand in Hand for Aid and Development is a Charitable Incorporated Organisation, number; 1176805, previously, 1145862.

As a multinational charitable organisation registered with England and Wales, Scottish German and Turkish charity commissions, we must comply with all relevant legislations in the jurisdictions in which the charity operates, in this instance most notably, the latest GDPR regulations as they came into effect on 25 May 2018. These data protection laws require us to protect personal information and control how it is collected, stored and used to ensure that it is used in accordance with the rights of data subjects and within the scope of charity law. All data subjects are entitled to know; their rights under the data protection act and how to use them what the charity is doing to comply with its legal obligations under GDPR.

2. This Policy

This Policy sets out the framework of governance and accountability for data protection compliance across the organisation and regulates;

Confidentiality: Protecting information from unauthorised access and disclosure

Integrity: Safeguarding the accuracy and completeness of information

Availability: Ensuring that information is available to data subjects whenever requested

Resilience: The ability to restore the security and access to information in the event of a technical or physical incident.

Hand in Hand for Aid and Development will apply the data protection principles and other requirements of data protection law to the management of all personal data throughout the information lifecycle by adopting the below principles.

3. Data Protection Principles

The Charity is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be: processed lawfully, fairly and in a transparent manner in relation to individuals; 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; adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed; accurate and, where necessary, kept up to date; every reasonable step must 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; 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; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and 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.”

4. General provisions

This policy applies to all personal data processed by the Charity.

The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy.

This policy shall be reviewed at least annually.

The Charity shall register with the Information Commissioner’s Office as an organisation that processes personal data.

5. Lawful, fair and transparent processing

To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.

The Register of Systems shall be reviewed at least annually. Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner.

6. Lawful purposes

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

The Charity 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 Charity’s systems.

7. Data minimisation

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

8. Accuracy

The Charity 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.

9. Archiving / removal

To ensure that personal data is kept for no longer than necessary, the Charity 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.

10. Security

The Charity 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. Physical information will be kept in a secure double locked location, access of which is limited to authorised personnel only.

11. 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 Charity shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO.


END OF POLICY