Data Protection Policy

Letton Hall Data Protection Policy

Letton Hall Trust (Letton) uses personal data about living individuals and organisations for the purpose of general administration, communication and facilitating use of our premises and services. Letton recognises the importance of the correct and lawful treatment of personal data. All personal data, whether on paper, on computer or other media, will be held subject to the provisions specified in the EU General Data Protection Regulation and subsequent UK laws implementing it.

Key principles are:

  1. That the data is fairly and lawfully processed
  2. That such data is processed and retained for limited purposes
  3. That the data retained is adequate, relevant and not excessive
  4. That the details are accurate (and maintained in an accurate state so far as is possible)
  5. That the data is kept no longer than is necessary
  6. Data is processed in accordance with the rights of the subjects
  7. That the data is held securely

For further information please visit: https://ico.org.uk

Letton fully endorses and adheres to these principles which 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 Letton must adhere to these principles.

This policy outlines our response to the above and our guidelines, principles and practice in respect of Data Protection.

 

Contents:

Introduction

Letton Hall purposes for collecting and retaining personal data

Applying the principles

Confidentiality

Our database

Rights to access information

Auditing and maintaining records

Children, vulnerable persons and sensitive information

 

Introduction

Data protection and the recording of data is the responsibility of the Letton Hall Centre Managers or staff authorised and overseen by them.

Letton Hall must have a lawful basis for collecting and holding any personal data. Letton Hall holds no data on individuals without either:

  1. The basis of consent (where someone has freely and clearly given their consent for the Trust to hold their information and for clear and limited purpose)

Currently Letton Hall has one postal mailing list, and every individual on that list has given their explicit consent to continue to receive newsletters and similar communications from Letton Hall Trust.

Additionally, Letton Hall has an online newsletter list, managed by MailChimp. Individuals on this list have either subscribed personally to the list or asked that their email address be added. This list is for the limited dissemination regular newsletters and updates regarding the work of Letton Hall Trust. Subscribers are automatically offered the opportunity to unsubscribe at any time (removal of consent) and, if they so choose, this is actioned immediately by the service provider.

  1. The basis of legitimate interest. In carrying out our work as a retreat and conference centre, it is necessary for Letton Hall to keep limited contact data concerning organisations and individuals. These records will fall into one of the following categories:
  1. Contacts in relation to bookings for retreats and conferences or individual contacts for Letton Hall events. These are recorded to enable effective communication between Letton Hall and our users, whether groups or individuals, strictly in relation to their bookings. By supplying information through our automated enquiry and booking forms, such data is automatically gathered in our online database and those supplying the information are made aware of this when they use this facility. This information is not used for any other purpose.
  2. Contact details for contractors, traders, suppliers and other mutually beneficial ‘business to business’ purposes. This is a dynamic database and will include those with whom we have regular or occasional business contact, to assist in the management of our facilities. This list is regularly audited to remove redundant contacts.
  3. Other personal contacts for staff, trustees, volunteers or other associates of the Trust, or individuals with whom Letton Hall Trust maintains a friendly connection.

Letton Hall purposes for collecting and retaining personal data

Letton may use your data for four main purposes:

  1. The day-to-day administration of The Letton Hall Trust e.g. staffing issues and administering the use of Letton Hall for conferences, retreats and other bookings and appropriate contact with user groups or their agents and representatives.
  2. For maintaining financial records of giving or payments to or from the Trust  
  3. For contacting supporters and friends to keep them informed of the work and activities of the Trust (our mailing lists are maintained in such a way that only those who have explicitly asked for communication will receive it)  
  4. For maintaining contact records of contractors or organisations who assist us in our work on a regular basis.

Applying the principles

  • All staff and volunteers who process Personal Data on behalf of Letton will be required to read and abide by this Data Protection Policy.
  • The Trust (Letton) delegates the day to day responsibility for the application of the policy and principles to the Centre Managers
  • When personal information is collected we will ensure that
    • this information is necessary for Letton’s purposes
    • the information is not kept for longer than it is needed
    • those people supplying the information are aware of this policy and how they can obtain a copy
    • Our database records and mailing lists are NEVER shared with any third party
  • Personal information (including photographs) of individuals will not be published on our website without obtaining explicit and informed consent from the individuals concerned or their parents (unless that information is already in the public domain). We will never publish the names of children and young people alongside their photographs.
  • We will ensure that information is readily available on our website and elsewhere as appropriate to ensure that subjects are aware of who to contact to update the information held about them by Letton.
  • A copy of this policy will be on the Letton website.
  • All personal information recorded by staff on behalf of Letton will be held and processed in a sufficiently secure manner (whether in paper or electronic form) to prevent unauthorised access (whether by unauthorised church staff or third parties). This means we will:
    • Store paper based information in secure, lockable cupboards
    • Use password protections and encryption of particularly sensitive electronic documents (all computers used to store sensitive information will be password protected and any mobile devices capable of accessing sensitive information must use a keyboard lock)
    • Restrict access to both paper and electronic personal data strictly to those who need to process it for one of the uses listed above.
    • Ensure that personal information is transmitted securely in a way that cannot be intercepted by unintended recipients

Confidentiality

Letton will treat all personal or organisational information as private and confidential and not disclose any data about you to anyone other than the staff and leadership of the Letton in order to facilitate the administration and day-to-day ministry of the Trust.

EXCEPTIONS

There are four exceptional circumstances to the above permitted by law:

  1. Where we are legally compelled to do so.
  2. Where there is a duty to the public to disclose.
  3. Where disclosure is required to protect your interest.
  4. Where disclosure is made at your request or with your consent.

Our database

Information contained on the database will not be used for any other purposes than those set out in this policy. The database is accessed through a remote server and therefore, can be accessed through any computer with internet access, subject to the points immediately below. The server for the database is located within the EU and managed by Croftsware Ltd, SHEEP CRM (http://getsheep.co.uk/).

  • Access to the database is available only to senior staff at Letton and is controlled through the use of name specific passwords.
  • People who will have secure and authorised access to the database include the Letton resident managers, who may also be responsible for inputting data
  • All access and activity on the database is logged and can be viewed by the management staff
  • Those utilising our automated enquiry and booking forms are advised that by so doing, they will be providing details that will populate this database

Our Newsletter mailing list is maintained by MailChimpⓇ and subscribers are free to unsubscribe at any time. This list is not used for any other purpose than newsletters and events information from Letton Hall.

Email Contacts lists

Letton Hall email accounts are stored with Google. As records are sometimes automatically created (by nature of the provision of this service), in order to maintain compliance with GDPR all outgoing emails carry a rider at the end of the message, explaining how individuals may have their records edited or deleted.

Rights to access information

Employees and other subjects of personal data held by Letton have the right to access any personal data that is being held in manual or online filing or database storage systems (subject to any lawful exemptions)

 

  • Subject Access – all individuals who are the subject of personal data held by Letton are entitled to:
    • Ask what information Letton holds about them and why
    • Ask how to gain access to it
    • Be informed how to keep it up to date
    • Be informed what Letton is doing to comply with its obligations in respect of EU GDPR and any UK law implementing it
  • Personal information will not be passed onto any third parties outside of the Trust environment
  • Personal Information may be withheld if the information relates to another individual
  • Subject Consent – The need to process data for normal purposes will be communicated to all data subjects. In some cases. If the data is or may be sensitive express consent to process the data must be obtained.

Any person who wishes to exercise their rights should make the request in writing to Centre managers at Letton Hall, or by email or telephone. A standard letter is available on line from www.ico.gov.uk

Letton aims to comply with requests for access to personal information as quickly as possible, but will ensure that it is provided within 28 days of receipt of a reasonable request unless there is good reason for delay. In such cases, the reason for delay will be explained in an appropriate manner to the individual making the request.

Auditing and maintaining records

Letton Hall Trust staff will ensure on an ongoing basis that details that are no longer valid for the purpose for which they were provided are removed from the database. This will be supported by an annual audit of the contacts database stored with Croftsware (as above).

The audit would include removal of contact details for individuals who are no longer the appropriate or active contact for the organisation concerned; individuals or groups who are no longer, or unlikely to be customers or users of Letton Hall; businesses, traders, contractors etc. with whom Letton Hall has had no recent contact or is unlikely to do in the foreseeable future.

Children, vulnerable persons and sensitive information

At the time of the latest revision, Letton Hall Trust has no requirement to record or retain personal information in respect of children or vulnerable persons. The Trust does not record or retain sensitive information at the present time. Should this situation change in the future, managers should undertake a Data Protection Impact Assessment (DPIA) before recording any such information.

REVISIONS

  • 1st draft – June 2016 by Daniel Pritchard, Centre Manager, Letton Hall Trust
  • 2nd draft – March 2018 by Daniel Pritchard, Centre Manager, Letton Hall Trust – this takes into account the requirements and provisions of the EU GDPR – Further edited 23 April 2018