The Lang Foundation Scottish Charity number SC017130

You must read this policy because it gives important information about:

• the data protection principles with which we must comply;
• what is meant by personal information (or data) and sensitive personal information (or data);
• how we gather, use and (ultimately) delete personal information and sensitive personal information in accordance with the data protection principles; and
• the consequences of failure to comply with this policy.
• Introduction
  • We obtain, keep and use personal information (also referred to as data) about job applicants, contacts at projects we support and about current and former volunteers and donors for a number specific lawful purposes.
  • This policy sets out how we comply with our data protection obligations and seek to protect personal information we hold.  Its purpose is also to ensure that we understand and comply with the rules governing the collection, use and deletion of personal information to which we may have access during our time at The Lang Foundation.
• Data protection principles
  • We will comply with the following data protection principles when processing personal information:
    • we will process personal information lawfully, fairly and in a transparent manner;
    • we will collect personal information for specified, explicit and legitimate purposes only, and will not process it in a way that is incompatible with those legitimate purposes;
    • we will only process the personal information that is adequate, relevant and necessary for the relevant purposes;
    • we will keep accurate and up to date personal information, and take reasonable steps to ensure that inaccurate personal information are deleted or corrected without delay;
    • we will keep personal information for no longer than is necessary for the purposes for which the information is processed; and
    • we will take appropriate technical and organisational measures to ensure that personal information are kept secure and protected against unauthorised or unlawful processing, and against accidental loss, destruction or damage.
• Privacy notice
  • Where appropriate, we will issue privacy notices from time to time, informing of the personal information that we collect and hold and how personal information is used and for what purposes.
  • We will take appropriate measures to provide information in privacy notices in a concise, transparent, intelligible and easily accessible form, using clear and plain language.
• Individual rights
  • Individuals have the following rights in relation to their personal information:
    • to be informed about how, why and on what basis that information is processed;
    • to obtain access to personal data held;
    • to have data corrected if it is inaccurate or incomplete;
    • to have data erased if it is no longer necessary for the purpose for which it was originally collected/processed, or if there are no overriding legitimate grounds for the processing (this is sometimes known as ‘the right to be forgotten’);

4.2       As an organisation, we need to comply with reasonable requests to exercise these rights.

• Storage and retention of personal information
  • Personal information (and sensitive personal information) will be kept securely.
  • Personal information (and sensitive personal information) should not be retained for any longer than necessary. The length of time over which data should be retained will depend upon the circumstances, including the reasons why the personal information was obtained.
  • Personal information (and sensitive personal information) that is no longer required will be deleted permanently from our information systems and any hard copies will be destroyed securely.
• Data breaches
  • A data breach may take many different forms, for example:
    • loss or theft of data or equipment on which personal information is stored;
    • unauthorised access to or use of personal information either by a member of staff or third party;
    • loss of data resulting from an equipment or systems (including hardware and software) failure;
    • human error, such as accidental deletion or alteration of data;
    • unforeseen circumstances, such as a fire or flood;
    • deliberate attacks on IT systems, such as hacking, viruses or phishing scams; and
    • ‘blagging’ offences, where information is obtained by deceiving the organisation which holds it.

• We will endeavour to:
  • make the required report of a data breach to the Information Commissioner’s Office without undue delay and, where possible within 72 hours of becoming aware of it, if it is likely to result in a risk to the rights and freedoms of individuals; and
  • notify the affected individuals if a data breach is likely to result in a high risk to their rights and freedoms and notification is required by law.
• Training

We will ensure that staff are adequately trained regarding their data protection responsibilities. Individuals whose roles require regular access to personal information, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.

• Consequences of failing to comply
  • We take compliance with this policy very seriously. Failure to comply with the policy:
    • puts at risk the individuals whose personal information is being processed; and
    • carries the risk of significant civil and criminal sanctions for the individual and the Company; and
    • may, in some circumstances, amount to a criminal offence by the individual.
  • 8.2           As an organisation we will take any failure to comply with any requirement of this policy seriously.
  • If you have any questions or concerns about anything in this policy, do not hesitate to contact the Board of Trustees.