1. Personal data is information about a person which is identifiable as being about them. It can be stored electronically or on paper, and includes images and audio recordings as well as written information.
2. Data protection is about how we, as an organization, ensure we protect the rights and privacy of individuals, and comply with the law, when collecting, storing, using, amending, sharing, destroying or deleting personal data.
1. Overall and final responsibility for data protection lies with the Executive Committee, who are responsible for overseeing activities and ensuring this policy is upheld.
2. All volunteers are responsible for observing this policy, and related procedures, in all areas of their work for the group.
3) Overall policy statement
1. Friends of Namibia Association needs to keep personal data about its committee, members, volunteers and supporters in order to carry out group activities.
2. We will collect, store, use, amend, share, destroy or delete personal data only in ways which protect people’s privacy and comply with the General Data Protection Regulation (GDPR) and other relevant legislation.
3. We will only collect, store and use the minimum amount of data that we need for clear purposes, and will not collect, store or use data we do not need.
4. We will only collect, store and use data for:
• purposes for which the individual has given explicit consent, or
• purposes that are in our our group’s legitimate interests.
We are also permitted to keep data to use it for: contracts with the individual whose data it is, or to comply with legal obligations, or to protect someone’s life, or to perform public tasks.
5. We will provide individuals with details of the data we have about them when requested by the relevant individual.
6. We will delete data if requested by the relevant individual, unless we need to keep it for legal reasons.
7. We will endeavour to keep personal data up-to-date and accurate.
8. We will store personal data securely.
9. We will keep clear records of the purposes of collecting and holding specific data, to ensure it is only used for these purposes.
10. We will not share personal data with third parties without the explicit consent of the relevant individual, unless legally required to do so.
11. We will endeavour not to have data breaches. In the event of a data breach, we will endeavour to rectify the breach by getting any lost or shared data back. We will evaluate our processes and understand how to avoid it happening again. If the data breach is serious (i.e. it may risk someone’s personal rights or freedoms) we will report it to the Information Commissioner’s Office (www.ico.org.uk) within 72 hours, and to the individual concerned.
12. To uphold this policy, we will maintain a set of data-protection procedures for our committee and volunteers to follow.
Sample data protection procedures
1. Friends of Namibia Association has a data-protection policy which is reviewed regularly. In order to help us uphold the policy, we have created the following procedures which outline ways in which we collect, store, use, amend, share, destroy and delete personal data.
2. These procedures cover the main, regular ways we collect and use personal data. We may from time to time collect and use data in ways not covered here. In these cases we will ensure our Data Protection Policy is upheld.
2) General procedures
1. Data will be stored securely. When it is stored electronically, it will be kept in password protected files. When it is stored online in a third-party website (e.g. Google Drive or MailChimp) we will ensure the third party comply with the GDPR. When it is stored on paper it will be filed carefully in a locked filing cabinet.
2. When we no longer need data, or when someone has asked for their data to be deleted, it will be deleted securely. We will ensure that data is permanently deleted from computers, and that paper data is shredded.
3. We will keep records of consent given for us to collect, use and store data. These records will be stored securely.
3) Mailing list
1. We will maintain a mailing list. This will include the names and contact details of people who wish to receive publicity and fundraising appeals from Friends of Namibia Association.
2. When people sign up to the list we will explain how their details will be used, how they will be stored, and that they may ask to be removed from the list at any time. We will ask them to give separate consent to receive publicity and fundraising messages, and will only send them messages which they have expressly consented to receive.
3. We will not use the mailing list in any way that the individuals on it have not explicitly consented to.
4. We will provide information about how to be removed from the list with every mailing.
5. We will use mailing list providers who comply with the requirements of the law and, if they store data outside the EU, comply with relevant data-protection requirements.
4) Purposes of mailings
1. We use the mailings primarily for contacting our members to inform them about meetings of the Friends of Namibia, activities of the member organizations, and other events, news and other content of potential interest to them.
2. We send mailings to other people who have consented to receive our mailings, with content meeting a similar description to the content sent to members.
3. We will also maintain lists of people who have attended events but ask if they are willing to be included in the wider mailing list, otherwise we will delete their details within 28 days after the event.
4. We will maintain other contacts and details for purposes relevant to the aims of Friends of Namibia. Anyone who suspects their information is held by Friends of Namibia is welcome to inquire to email@example.com.
5) Contacting committee members
1. The committee need to be in contact with one another in order to run the organization effectively and ensure its legal obligations are met.
2. Committee contact details will be shared among the committee.
3. Committee members will not share each other’s contact details with anyone outside of the committee, or use them for anything other than Friends of Namibia Association business, without explicit consent.
6) Deletion of data
For your safety, we will delete any records that have not been used for 24 months, including if you have not opened any emails to read them over the preceding 24 months.
Page updated 23 November 2020