The Karten Network holds and processes information, including Appendix 1. This policy outlines how we protect the data we hold. The Karten Network undertakes to ensure that consultants delivering services understand the rules governing their use of personal data. There is a requirement that the Data Protection Officer (DPO) is consulted before any new data processing activities occur to ensure that relevant compliance steps are addressed.
The Karten Network believes that transparency and providing accessible information to individuals about how we will use their personal data is very important. This policy and procedures will be fully implemented by 25 May 2018 ensuring full GDPR compliance.
This policy applies to all Consultants and professionals delivering services for the Karten Network, they must be familiar with this policy and comply with its terms. The policy will be reviewed and updated on an annual basis, any amendments will be circulated to professionals prior to implementation.
The accountability rests with the Karten Network Board and the Network Chair who delegate responsibility to the Karten Network Development Co-ordinator. Dawn Green (Karten Network Development Co-ordinator and DPO) has overall responsibility for the day-to-day implementation of this policy.
The following principles will be applied to all aspects of collection, storage and processing of personal data:
- Personal data shall be processed fairly and lawfully
- Personal data shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes
- Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed
- Personal data shall be accurate and, where necessary, kept up to date
- Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes
- Personal data shall be processed in accordance with the rights of data subjects
- Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data
- Personal data shall 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. [Note that some of the organisations we work with are outside the European Economic Area, e.g. Israeli Karten Centres outside. The same degree of data protection is applied when storing and processing data provided by such organisations.]
The purposes for which personal data may be used include but are not limited to:
Personnel, administrative, financial, regulatory, payment, sharing practice and network development purposes.
Information relating to identifiable individuals, such as consultants, Karten Centre staff and users, suppliers and marketing contacts. We do not hold or process any sensitive personal data.
Fair and lawful processing
We must process personal data fairly and lawfully in accordance with individuals’ rights. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening.
The Data Protection Officer’s responsibilities
- Keeping the Karten Network Board updated about data protection responsibilities, risks and issues
- Reviewing all data protection procedures and policies on a regular basis
- Arranging data protection training and advice for all consultants
- Answering questions on data protection from consultants, board members and other stakeholders
- Responding to individuals who wish to know what data is being held on them by the Karten Network
- Ensure all marketing and communication initiatives adhere to data protection laws and the Data Protection Policy
Responsibilities of the Mobile Technology Adviser
- Ensure all systems, services, software and equipment meet acceptable security standards
- Checking and scanning security hardware and software regularly to ensure it is functioning properly
- Researching third-party services, such as cloud services the company is considering using to store or process data
- Approving data protection statements attached to emails
The processing of all data must be
- Necessary to deliver Karten Network services and support
- In the Karten Network’s legitimate interests and not unduly prejudice the individual’s privacy
- In most cases this provision will apply to routine business data processing activities
The Karten Network has a Privacy Notice to inform stakeholders about our data protection procedures. This notice
- Sets out the purposes for which we hold and process personal data
- Informs stakeholders that they have a right of access to the personal data that we hold about them
Accuracy and relevance
The Karten Network will ensure that any personal data processed is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.
Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the details and inform the DPO, Dawn Green.
Your personal data
You must take reasonable steps to ensure that personal data we hold about you is accurate and updated as required. For example, if your personal circumstances change, please inform the Data Protection Officer so that they can update your records.
We will take necessary steps to keep personal data secure against loss or misuse. On the rare occasions that other organisations process personal data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.
Maintaining appropriate standards of data protection is a collective task. All personal data must be secured against loss or misuse.
User names and passwords may not be shared except for the disaster recover policy or when a shared account is used.
Storing data securely
- Where data is stored on paper this must be stored securely and only be accessible to people with the necessary authorisation. The access to this data must be limited to the specific task/s for which the data is required
- All paper-based data should be shredded when it is no longer needed (see data retention)
- Data stored on CDs, DVDs or tapes must be locked away securely and only be accessible to people with the necessary authorisation. The access to this data must be limited to the specific task/s for which the data is required
- All CDs, DVDs or tapes media must be physically destroyed or erased when it is no longer needed (see data retention)
- All removable storage devices (e.g. Flash drives, external hard drives, network attached storage) must be encrypted and password protected. When not in use these devices must be locked away securely. Access to these devices and the data contained on them must only be accessible to people with the necessary authorisation
- The access to this data must be limited to the specific task/s for which the data is required
- All data contained on removable storage devices must be erased when it is no longer needed (see data retention)
- Computers used for Karten Network activities must be configured with a user name and a unique, sufficiently complex password
- Computer systems must have real-time anti-virus, anti-malware and anti-spyware software installed, preferably with firewall software too
- All data contained on a computer must be erased when it is no longer needed (see data retention)
- All mobile devices used for Karten Network activities must be configured with a PIN (or equivalent security measure)
- All data contained on a mobile must be erased when it is no longer needed (see data retention)
- Servers containing personal data must be kept in a secure location and must require a user name and password to access them. Access to servers must be limited to people with the necessary authorisation. The data accessed must be limited to the specific task/s for which the data is required
- Software updates and security patches must be applied to all systems as soon as possible
- Appropriate and secure backing up of data must be done regularly. All data contained within a backup must be erased when it is no longer needed (see data retention)
- Firewalls and security settings must be enabled on routers within our control
- Access to areas of the website containing personal data, with the exception of the public accessible centre information, must require a user name and password and be limited to the appropriate authorised access
- All e-mail sent using the karten-network.org.uk domain must be encrypted and transmitted over a secure connection
- Access to cloud-based services (e.g. Microsoft OneDrive, Yammer) must require a username and secure password. All cloud-based services must have adequate security measures in place
- The DPO must approve any cloud used to store data
We will not retain personal data for any longer than is necessary. What is deemed necessary will depend on the circumstances of each case, considering the reasons that the personal data was obtained, but should be determined in a manner consistent with current data retention guidelines.
Consultant details are kept during their service and removed when their contract finishes. Centre contact details are kept whilst they have a viable Karten Centre.
Transferring data internationally
There are restrictions on international transfers of personal data. Personal data will not be transferred outside the UK without first consulting the Data Protection Officer.
Subject access requests
Under the Data Protection Act 1998, individuals are entitled, subject to certain exceptions, to request access to information held about them. If a subject access request is received it will be referred immediately to the DPO for relevant action.
Processing data in accordance with the individual’s rights
We will abide by any request from an individual not to use their personal data for purposes other than those agreed. Consent will be sought before passing contact data on to any other stakeholder.
Being transparent and providing accessible information to individuals about how we will use their personal data is important to the Karten Network.
Conditions for processing
We will ensure that any use of personal data is justified using at least one of the conditions for processing. Professionals who are responsible for processing personal data will be aware of the conditions for processing. The conditions for processing will be available to data subjects in the form of a privacy notice.
Justification for personal data
We will process personal data in compliance with the data protection principles specified earlier in this policy (Principles).
The data that we collect is subject to active consent by the data subject. This consent can be revoked at any time.
Upon request, a data subject should have the right to receive a copy of their data in a structured format. These requests should be processed within one month, provided there is no undue burden and it does not compromise the privacy of other individuals. A data subject may also request that their data is transferred directly to another system. This must be done for free.
Right to be forgotten
A data subject may request that any information held on them is deleted or removed, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies.
Privacy by design and default
Privacy by design is an approach to projects that promote privacy and data protection compliance from the start. The DPO will be responsible for conducting Privacy Impact Assessments and ensuring that all new projects commence with a privacy plan.
When relevant, and when it does not have a negative impact on the data subject, privacy settings will be set to the most private by default.
International data transfers
No data may be transferred outside of the UK without first discussing it with the DPO. Specific consent from the data subject must be obtained prior to transferring their data outside the UK.
Data audit and register
Regular data audits to manage and mitigate risks will inform the data register. This contains information on what data is held, where it is stored, how it is used, who is responsible and any further regulations or retention timescales that may be relevant.
All professionals have an obligation to report actual or potential data protection compliance failures. This allows us to:
- Investigate the failure and take remedial steps if necessary
- Maintain a register of compliance failures
- Notify the Supervisory Authority (SA) of any compliance failures that are material either in their own right or as part of a pattern of failures
Monitoring and compliance
All consultants and professionals delivering services for the Karten Network must observe this policy. The DPO has overall responsibility for this policy and will monitor it regularly to make sure it is being adhered to.
Consequences of failing to comply
The Karten Network takes compliance with this policy very seriously. Failure to comply puts the organisation at risk.
The importance of this policy means that failure to comply with any requirement may lead to disciplinary action under our procedures which may result in termination of your Consultancy Agreement.
Any questions or concerns regarding this policy should be directed to the DPO.