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 data protection legislation.
Who are we?
The Finderne Development Trust (FDT) is the data controller (contact details below). This means FDT decides how your personal data is processed and for what purposes. The FDT may also be the data processor.
The Administrative Officer of the FDT fulfils the role of the Data Protection Officer for the FDT.
How do we process your personal data?
The FDT complies with its obligations under data protection legislation 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 personal data in order to meet the constitutional objectives of the Finderne Development Trust as set out in its Articles of Association – see FDT Articles of Association April2018
What is the legal basis for processing your personal data?
Explicit consent from members of FDT, so that we can keep you informed about news, events, activities and consultations, and so that we can seek your opinions on various issues;
Processing is necessary for carrying out obligations under the FDT’s Articles of Association;
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
Processing is necessary for compliance with a legal obligation to which the controller is subject;
Processing is necessary in order to protect the vital interests of the data subject or of another natural person;
Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Data Storage and Security
The FDT stores personal data within the contacts list within its email system, within emails, and for financial transaction within its accounts.
Only members of the FDT Board and FDT staff have a password to access the email system, and should not divulge the password. The password will be changed on a regular basis at least annually, and whenever a Director / member of staff leaves the FDT.
Personal data in the contacts list is labelled as “FDT members”, “Organisations”, “Member Directors”, “Suppliers and Service Providers” etc., as appropriate.
Group emails to FDT Members will use the “blind copy” technique, in order to keep contact data confidential, and offer the recipients the opportunity to unsubscribe.
We may also share data relating to financial transactions with professional auditors, who themselves will be data protection compliant.
Personal data may also be recorded within the minutes of FDT meetings, for which prior consent will be obtained.
Sharing your personal data
Your personal data will be treated as strictly confidential. We will only share your data with third parties with your consent, or for reasons identified is section 4 above.
How long do we keep your personal data?
We keep data only as long as it is needed.
FDT Members will be contacted every 2 years, to refresh consent to hold personal data.
The entire contacts list will be reviewed every 2 years, and redundant data will be deleted.
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 the FDT holds about you;
- The right to request that the FDT 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 the FDT to retain such data;
- The right to withdraw your consent to the processing at any time;
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request that a restriction is placed on further processing;
- 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 Privacy Notice, then we will inform our contacts, and update this 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.
To exercise all relevant rights, queries or complaints please in the first instance contact the Administrator via our contact page Contact or by post to Finderne Development Trust c/o 100 High street, Forres, Moray, IV36 1PD (Registered Office).
If not satisfied, you can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
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