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Data Protection 2018

General Data Protection Policy and Procedures (As adopted 23rd May 2018 at AGM)

The new General Data Protection Regulations (GDPR) were published in 2016 and in came into force  on 25 May 2018. The legislation provides key changes that are addressed by  MRCAS in this policies,  privacy notice and consent form. 

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The National Allotment Society (NSALG) of which we are members, has provided guidance which MRCAS has used to formulate this policy.  

 

Principles

 

  1. Personal data must be processes fairly and lawfully and in a transparent manner.

  2. Personal Information must be collected for specified, explicit and legitimate reasons.

  3. Personal data must be adequate, relevant and limited to what is necessary for the purpose.

  4. Personal data must be up to date and accurate.

  5. Personal data must not be kept longer than is necessary.

  6. Personal information must be processed in a manner which ensures security of the personal data against unlawful processing, accidental loss, destruction or damage.

 

 

Personal Data

It has been determined that only basic and NO Sensitive Personal Data is collected by MRCAS (as defined in the Regulations). 

 

Data Protection Policy following the 5 whys principle:

 

Why  - the purpose /reason for holding data 

 

For communication and notification of important information related to the upkeep, security and management of the allotment. Via email or website.

 

For the collection of rent

 

To provide membership details to National Allotment Society in order to pay annual membership (Name Only) provided.  NSALG have an internal policy for ensuring this information is kept private and not shared.

 

 

What – what data is being held

Name (Including that of any named person on the tenancy Agreement), Postal Address, Telephone Contact details (Land and Mobile), email address

 

 

Who - whose data do we hold

Plot holders  and those on the Waiting List

 

Where - is the data held

With Committee Officials usually the Chairman, Secretary or Treasurer

Held electronically on a secure computer

Signed Tenancy/ Consent  agreements - paper copies with current Secretary

 

When – for how long is the data held

Plot holders – as long as the member has a plot on Moss Row. 

 

Waiting List – until the person on the waiting list confirms they no longer wish to be on the list or have been removed following a list review. Or they have failed to communicate their consent for holding information.

 

Procedures for Management of data

 

MRCAS Officials will ensure that:

 

Data will be safeguarded and not shared with 3rd parties other than email address to other plot holders, unless they have elected that they do not wish for email address to be shared in communications.

 

Members and Waiting list applicants continue to be informed of what is kept and why and for how long.

 

That data will be removed/destroyed when Members or Applicants leave or no longer wish to be listed.

 

Any data breaches or losses will be communicated promptly to the owners of the data.

 

 

Tenants:

 

  • Plot becomes available when tenant leaves (records removed from lists by MRCAS)

  • Plot offered and Tenancy/Consent signed and kept by MRCAS Officials

  • New tenant information (as described) and details stored electronically and used as described

 

Waiting List:

 

  • Enquiries received via the website (Secretary)

  • Standard Response issue asking for personal details including consent for details to be held on an electronic list.  (Information relating to length of time to wait is given which often prevents further interest in being on the list)

  • Information passed to Chairman who adds person to Master List

  • List reviewed periodically – failure to respond results in person being permanently removed from Master List

 

 

 

Security:

As the data kept by MRCAS by the Chairmen is none Sensitive (as defined) and it is felt that the level of security for electronic data kept is adequate for this level of data.  That being, stored on a secure computer with up to date software, security and network protection. 

 

NO INFORMATION is shared with ANY 3rd Parties, with the exception NSALG as part of our membership requirements (Names Only).

 

 

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