The types of personal data that we may be required to handle include information about current, past and prospective members and others with whom it communicates.  The personal data, which may be held on paper or on a computer or other media, is subject to certain legal safeguards specified in the Data Protection Act 1998 (the Act) and other regulations.

 

This policy sets out our rules on data protection and the eight data protection principles contained in it.  These principles specify the legal conditions that must be satisfied in relation to the obtaining, handling, processing, transportation and storage of personal data.

 

Data is recorded information whether stored electronically, on a computer, or in certain paper-based filing systems.

Data subjects for the purpose of this policy include all living individuals about whom we hold personal data.  All data subjects have legal rights in relation to their personal information.

Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (such as a performance appraisal).

Data controllers are the people or organisations who determine the purposes for which, and the manner in which, any personal data is processed. They have a responsibility to establish practices and policies in line with the Act. We are the data controller of all personal data used in our business.

Data processors include any person who processes personal data on behalf of a data controller.

Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.

Sensitive personal data includes information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive personal data can only be processed under strict conditions, including a condition requiring the express permission of the person concerned.

 

Anyone processing personal data must comply with the eight enforceable principles of good practice.  These provide that personal data must be:

·         processed fairly and lawfully;

·         processed for limited purposes and in an appropriate way;

·         adequate, relevant and not excessive for the purpose;

·         accurate;

·         not kept longer than necessary for the purpose;

·         processed in line with data subjects' rights;

·         secure; and

·         not transferred to people or organisations situated in countries without adequate protection.

 

The Act is intended not to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject. The data subject must be told who the data controller is (in this case Cardiff Business Club Limited), the purpose for which the data is to be processed, and the identities of anyone to whom the data may be disclosed or transferred.

For personal data to be processed lawfully, certain specific conditions have to be met.  These include, among other things, requirements that the data subject has consented to the processing, or that the processing is necessary for the legitimate interest of the data controller or the party to whom the data is disclosed.  When sensitive personal data is being processed, additional conditions must be met.  In most cases the data subject's explicit consent to the processing of such data will be required.

 

Personal data may only be processed for the specific purposes notified to the data subject when the data was first collected or for any other purposes specifically permitted by the Act.  This means that personal data must not be collected for one purpose and then used for another.  If it becomes necessary to change the purpose for which the data is processed, the data subject must be informed of the new purpose before any processing occurs.

 

Personal data should only be collected to the extent that it is required for the specific purpose notified to the data subject.  Any data which is not necessary for that purpose should not be collected in the first place.

 

Personal data must be accurate and kept up to date.  Information which is incorrect or misleading is not accurate and steps should therefore be taken to check the accuracy of any personal data at the point of collection and at regular intervals afterwards.  Inaccurate or out-of-date data should be destroyed.

 

Personal data should not be kept longer than is necessary for the purpose. This means that data should be destroyed or erased from our systems when it is no longer required.

 

Data must be processed in line with data subjects' rights.  Data subjects have a right to:

·         request access to any data held about them by a data controller;

·         prevent the processing of their data for direct-marketing purposes;

·         ask to have inaccurate data amended; and

·         prevent processing that is likely to cause damage or distress to themselves or anyone else.

 

We must ensure that appropriate security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.

We are required by the Act to put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data may only be transferred to a third-party data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.

Maintaining data security means guaranteeing the confidentiality, integrity and availability of the personal data, defined as follows:

·         Confidentiality means that only people who are authorised to use the data can access it.

·         Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.

·         Availability means that authorised users should be able to access the data if they need it for authorised purposes.

 

A formal request from a data subject for information we hold about them must be made in writing. Such a request can be made to RPA House, St. Mellons Business Park, Cardiff CF3 0EY.