Privacy Policy

Updated: 20th August 2012, 12th July 2011, 12th July 2010 and 24th September 2009, 30th May 2017

Adopted on the 30th November 2009

Reviewed on 30th May 2017

SEED is required to maintain certain personal data about living individuals for the purposes of satisfying operational and legal obligations. SEED recognises the importance of the correct and lawful treatment of personal data; it maintains confidence in the organisation and provides for successful operations.

The types of personal data that SEED may require includes information about: current, SEED volunteers; SEED members; suppliers and others with whom they communicate.

This personal data, whether it is held on paper, on computer or other media, will be subject to the appropriate legal safeguards as specified in the Data Protection Act 1998.

SEED fully endorses and adheres to the eight principles of the Data Protection Act. These principles specify the legal conditions that must be satisfied in relation to obtaining, handling, processing, transportation and storage of personal data. Employees and any others who obtain, handle, process, transport and store personal data for the Company must adhere to these principles.

Principles

The principles require that personal data shall:

1. Be processed fairly and lawfully and shall not be processed unless certain conditions are met;
2. Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose;
3. Be adequate, relevant and not excessive for those purposes;
4. Be accurate and, where necessary, kept up to date;
5. Not be kept for longer than is necessary for that purpose;
6. Be processed in accordance with the data subject’s rights;
7. Be kept secure from unauthorised or unlawful processing and protected against accidental loss, destruction or damage by using the appropriate technical and organisational measures;
8. And not be transferred to a country or territory outside the European Economic Area, unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

Satisfaction of principles

In order to meet the requirements of the principles, SEED will:

• observe fully the conditions regarding the fair collection and use of personal data;
• meet its obligations to specify the purposes for which personal data is used;
• collect and process appropriate personal data only to the extent that it is needed to fulfil operational or any legal requirements;
• ensure the quality of personal data used;
• apply strict checks to determine the length of time personal data is held;
• ensure that the rights of individuals about whom the personal data is held, can be fully exercised under the Act;
• take the appropriate technical and organisational security measures to safeguard personal data by sending emails to undisclosed recipients at all times when distributing from mailing lists and sending emails to multiple recipients;
• and ensure that personal data is not transferred abroad without suitable safeguards.

SEED’S Designated Data Controller

SEED Secretary and Administrator is responsible for ensuring compliance with the Data Protection Act and implementation of this policy. Any questions or concerns about the interpretation or operation of this policy should be taken up in the first instance with Marg Oaten as the point of contact.

Status of the Policy

This policy has been approved by the Trustee’s and any breach will be taken seriously and may result in formal action.

Any volunteer or paid sessional worker who considers that the policy has not been followed in respect of personal data about themselves should raise the matter with the Secretary in the first instance.

Subject Access

All individuals who are the subject of personal data held by SEED are entitled to:

• Ask what information SEED holds about them and why
• Ask how to gain access to it
• Be informed how to keep it up to date
• Be informed what SEED is doing to comply with its obligations under the 1998 Data Protection Act

Volunteer Responsibilities

All volunteers are responsible for:

• Checking that any personal data that they provide to SEED is accurate and up to date
• Informing SEED of any changes to information which they have provided, e.g. changes of address
• Checking any information that SEED may send out from time to time, giving details of information that is being kept and processed

If, as part of their responsibilities, volunteers collect information about other people (e.g. about personal circumstances, or about employees in the company), they must comply with the Policy and with the Data Protection Procedures.

Data Security

The need to ensure that data is kept securely means that precautions must be taken against physical loss or damage, and that both access and disclosure must be restricted. All volunteers and paid sessional workers are responsible for ensuring that:

• Any personal data which they hold is kept securely
• Personal information is not disclosed either orally or in writing or otherwise to any unauthorised third party

Rights to Access Information

Volunteers, members and other subjects of personal data held by SEED have the right to access any personal data that is being kept about them on computer and also have access to paper-based data held in certain manual filing systems. This right is subject to certain exemptions which are set out in the Data Protection Act. Any person who wishes to exercise this right should make the request in writing to SEED Secretary.

If personal details are inaccurate, they can be amended upon request.

SEED aims to comply with requests for access to personal information as quickly as possible, but will ensure that it is provided within 40 days of a written request, unless there is good reason for delay. In such cases, the reason for delay will be explained in writing to the individual.

Publication of Company Information

Information that is already in the public domain is exempt from the 1998 Act. This would include, for example, information on volunteers and paid sessional workers contained within externally circulated publications such as the SEED Newsletter. Any individual who has good reason for wishing details in such publications to remain confidential should contact the SEED Secretary.

Subject Consent

The need to process data for normal purposes has been communicated to all data subjects. In some cases, if the data is sensitive, for example information about health, race or gender, express consent to process the data must be obtained. Processing may be necessary to operate SEED policies, such as health and safety and equal opportunities.

Retention of Data

SEED will keep some forms of information for longer than others. All volunteers are responsible for ensuring that information is not kept for longer than necessary.

SEED Eating Disorder Support Services - The Resource Room, 267 Beverley Road, Hull HU5 2ST

Admin (01482) - 344084 Helpline (01482) 718130 - Charity No. 1108405

Email: toolkit@seedeatingdisorders.org.uk

Website: www.seedeatingdisorders.org.uk