Policy Review Date: May 2020
Mull and Iona Community Trust (MICT) is the data controller which means it decides how your personal data is processed and for what purposes.
Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the GDPR).
How do we process your personal data?
Mull and Iona Community Trust complies with its obligations under [the GDPR] by keeping personal data up to date;
by storing and destroying it securely; by not collecting or retaining excessive amounts of data;
by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We use your personal data for the following purposes:
To administer membership records;
To promote the interests of the charity;
To manage our employees and volunteers;
To maintain our own accounts and records.
Our processing also includes the use of CCTV systems for the prevention of crime.
To operate the MICT web site and deliver the services that individuals have requested.
To inform individuals of news, events, activities or services run by the MICT.
To process gift aid applications.
To contact individuals via surveys to conduct research about their opinions of current services or of potential new services that may be offered.
What is the legal basis for processing your personal data?
Article 6 processing
Consent of the data subject:
Membership Form completion
Consent Form as detailed in Appendix 1
Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract
Consent of the data subject:
Mull and Iona Community Trust
An Roth – Community Enterprise Centre
Processing is necessary for compliance with a legal obligation:
OSCR requires that we “Keep registers of charity trustees and of members”.
Companies House requires that we keep registers of Directors and their usual residential addresses.
Processing is necessary for the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject.
The MICT Articles of Association state that a register of members be maintained setting out for each current member.
The organisations / individuals full name and address.
The date on which they registered as a member of the organisation
The category of membership
The date on which any individual / organisation ceased to be a member
Former member records must be retained for 6 years from the date they ceased to be a member.
Grant Funding reporting and monitoring requirements state that “the Grantee must keep and maintain for a period of between 6-12 years adequate and proper records in hard copy format and books of account” depending on the Funder.
The Mull and Iona Community Trust does not process or hold any Special Categories of Personal Data as per Article 9 or the GDPA.
Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with other organisations to comply with a legitimate interest or a legal obligation i.e OSCR, Companies House or Funders.
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary but for a period of 6 -12 years in order to comply with our Company requirements and Funding obligations.
HR Payroll data is kept for a period of at least 3 years following the termination of employment and all Personnel records are kept for 5 years.
Your rights and your personal data
Unless subject to an exemption [under the GDPR], you have the following rights with respect to your personal data:
The right to request a copy of your personal data which MICT holds about you;
The right to request that MICT corrects any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary for MICT to retain such data;
The right to withdraw your consent to the processing at any time;
The right to request that MICT provide the data subject with his/her personal data and where possible, to transmit that data directly to another data controller, known as the right to data portability, (where applicable).
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable).
The right to lodge a complaint with the Information Commissioners Office.
If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing. Contact Details To exercise all relevant rights, queries of complaints please in the first instance, contact us at: firstname.lastname@example.org