Table of contents
Data protection lead
Data protection lead
Our data protection lead is the Finance and Business Director, Liz Ambekar.
Commencement of this policy
This policy shall be deemed effective as of 25/05/2018 however it will not have effect retrospectively and will apply only to matters occurring after this date.
In relation to our use of personal data we take the following measures:
- Encryption: Encryption is in place across a number of systems and reviews are taking place.
- Erasure, destruction or deletion: In accordance with data retention policy.
- Transmission via email: Personal data is only transmitted by BSI via secure email
- Transmission of hard copies: Any personal data being sent in hard copy would be sent using secure means.
- Transmission via networks: Managed by IT. New systems in implementation with details to follow.
- Storage of emails and email content: Emails retained in accordance with retention policy.
- Access of employees: All employees have signed data protection clauses in their employment contracts. Access to personal data is limited to those employees who require it to undertake their roles. Controls are in place to ensure that different data is accessed according to role.
- Access of third parties: Third party access is only given to companies who are providing services which require access and is not shared more widely.
- Storage of hardcopies: Personal data held in hard copy is held securely either within the office or at Iron Mountain storage. Only authorised personnel have access to the data.
- Storage of electronic copies: Secure file storage system (filecsync) in place with only authorised personnel able to access.
- Sharing: Third party sharing only occurs with companies who are undertaking work on behalf of the BSI, i.e. mailing houses.
- Viewing on systems: All systems have security in place and only authorised personnel able to access.
- Viewing on devices: Only authorised personnel able to view on devices and policies in place.
- Passwords: All devices and systems are password protected.
We may collect, hold and/or process the following personal data. This list may not be exhaustive but is kept as up to date as possible.
- Membership information: Information for membership applications and management including name, contact details, date of birth, nationality, place of work / study and bank information for direct debits. All information is held securely on our membership database.
- Event attendee information: Information from event attendees including registration data (name, contact details, place of work / study, gender, access requirements, dietary requirements).
- Employee information: Personal data needed to manage employment including contracts, references, performance records, payroll information and absence information.
- Payment information for expenses and other payments: Personal information required to ensure payment including bank details, contact details and expense claims.
- Grant and other awards applications and information: Personal information required to process grant and other award applications. Including name, contact details, place of work, qualifications, work and educational experience.
- Information from surveys and other forms: Personal information given as part of a survey or other form. This may include name, contact information and responses to questions asked.
1. The reason for this policy
1.1 You have legal rights with regard to the way your personal data is handled.
1.2 In the course of our activities we collect, store and process personal data about our customers, suppliers and other third parties and therefore, in order to comply with the law and to maintain confidence in our business, we acknowledge the importance of correct and lawful treatment of this data.
1.3 All people working in or with our organisation are obliged to comply with this policy when processing personal data
2.1 This policy and any other documents referred to in it sets out the basis on which we will process any personal data we collect from data subjects, for example, members or other contacts, or that is provided to us by data subjects or other sources.
2.2 In this policy when we say “you" or “your” we are generally referring to the data subjects unless the context requires otherwise.
2.3 It also sets out our obligations in relation to data protection under the General Data Protection Regulation 2016 (“the GDPR Rules”).
2.4 This policy sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer and store personal data.
2.5 We agree to ensure that all of our directors, employees, consultants and agents comply with this policy.
2.6 We aim to ensure the correct, lawful, and fair handling of your personal data and to respect your legal rights.
3. The meaning of key data protection terms
3.1 data is information which is stored electronically, on a computer, or in certain paper-based filing systems.
3.2 data subjects for the purpose of this policy include all living individuals about whom we hold personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal information.
3.3 personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (for example, a name, address or date of birth) or it can be an opinion about that person, their actions and behaviour.
3.4 data controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed. They are responsible for establishing practices and policies in line with the Act. We are the data controller of all personal data used in our organisation.
3.5 processing is any activity that involves use of personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
4. Summary of the data protection principles
This policy aims to ensure compliance with the GDPR Rules. The GDPR Rules sets out the following principles with which any party handling personal data must comply. All personal data must be:
- Processed fairly and lawfully – it must be processed fairly and lawfully and it must be processed – in relation to you as the data subject – in a transparent manner
- Processed for limited purposes and in an appropriate way – the purposes for which it is collected must be explicit, specified and legitimate
- Adequate, relevant and not excessive for the purpose
- Accurate – as well as being accurate it must be kept up to date with inaccurate data deleted
- Not kept longer than necessary for the purpose
- Processed in line with data subject's rights
- Security – there must appropriate technical or organisational measures to ensure appropriate security
In addition, personal data must not be transferred outside the European Economic Area (the “EEA”) without adequate protection.
5. Notifying data subjects
5.1 As part of complying with the principles in para 4 above, if you provide us with personal data we will always try to tell you:
5.1.1 the purpose or purposes for which we intend to process that personal data
5.1.2 the types of third parties, if any, with which we will share or to which we will disclose that personal data
5.1.3 how you can limit our use and disclosure of their personal data
5.1.4 if we receive personal data from other sources.
6. Lawful, fair, and transparent data processing
The GDPR Rules are not intended to prevent the processing of personal data but to ensure that it is done fairly and without adversely affecting your rights. The processing of personal data is lawful if one (or more) of the following applies:
- (consent) the data subject has consented for a specific purpose;
- (contract) if the data subject requests the processing with a view to entering into a contract or the processing is necessary for the performance of a contract
- (legal obligation) if the processing is necessary for the compliance with a legal obligation to which the data controller is subject
- (protection) processing is necessary to protect your vital interests or those of another natural person
- (public interest) it is in the public interest for a task to be carried out which requires such processing, or the task is to be carried out as a result of the exercise of any official authority held by the data controller;
- (legitimate interests) for the legitimate interest of the data controller or the party to whom the personal data is disclosed.
7. Processed for limited purposes and in an appropriate way
7.1 In the course of our business, we may collect and process the personal data set out above. This may include personal data we receive directly from you (for example, by completing forms or by corresponding with us by mail, phone, email or otherwise) and data we receive from other sources (including, for example, business partners, sub-contractors in technical, payment and delivery services and others).
7.2 We will only process personal data for the specific purposes set out above or for any other purposes specifically permitted by the GDPR Rules. We will notify those purposes to you when we first collect the personal data or as soon as possible thereafter.
8. Adequate, relevant and not excessive for the purpose
We will only collect and process personal data for the specific purpose(s) set out above.
9. Accuracy of data and keeping data up to date
We will keep your personal data accurate and up-to-date. We will check its accuracy regularly. When we find inaccurate or out-of-date data, we will take reasonable steps to amend or erase that data.
10. Timely processing
We will only keep your personal data for a period of time which we judge is relevant and necessary taking into account the purpose(s) of collecting the personal data which are specified above.
11. Processing that is secure
In addition to the measures above:
11.1 we will make sure that the personal data we collect is securely kept and we stop unauthorised processing and prevent its loss, destruction or damage
11.2 we will ensure that only people who are authorised to use personal data can access it and that we have entry controls to our premises and systems, lockable desks and cupboards for confidential personal data and destruction of hard copy documents and digital storage devices
11.3 all authorised persons must ensure that individual monitors do not show confidential information to passers-by and that they log off from their PC when it is left unattended.
12. You, as a data subject, have the right to information about:
- who we are
- the purpose(s) of collecting your personal data and the legal basis for collecting it and what our legitimate interest is for processing your personal data
- the categories of personal data collected and where is to be transferred, especially if outside the EEA
- the length of time we hold personal data (or, where there is no predetermined period, details of how that length of time will be determined)
- your rights as a data subject including your right to withdraw your consent to processing, the right to complain to the Information Commissioner and also things such as details of any legal requirement for processing personal data that may exist and any automated decision-making that we carry out.
We will try to provide this information when we collect the personal data or, if we collect the personal data from another party, when we communicate with you after the personal data is received.
13. Data subject access
13.1 You may request access to any data held about you by us (a subject access request (“SAR”)
13.2 We reserve the right to charge reasonable fees for onerous or repetitive requests.
13.3 Data subjects must make a formal request for information we hold about them. This must be made in writing. To make a formal request please write to Data Manager, British Society for Immunology, 34 Red Lion Square, London, WC1R 4SG or email firstname.lastname@example.org.
13.4 When receiving telephone enquiries, we will only disclose personal data we hold on our systems if the following conditions are met:
a) we will check the caller's identity to make sure that information is only given to a person who is entitled to it.
b) we will suggest that the caller put their request in writing if we are not sure about the caller’s identity and where their identity cannot be checked.
14. Accuracy of personal data: right to rectification
14.1 We will do our best to ensure that all personal data held about you is accurate and complete. We ask that you notify us of any changes to information held about you. To notify us of changes to information held about you please either login in to your account on www.immunology.org, write to us at Membership Office, 34 Red Lion Square, London, WC1R 4SG or email email@example.com.
14.2 You have the right to request that any incomplete or inaccurate information held about you is rectified and to lodge a complaint with us and the Information Commissioner's Office.
14.3 We will respond to requests to rectify within one month.
15. Right to be forgotten
You have the right to request the deletion or removal of personal data however requests for erasure can be rejected in certain circumstances. Where possible personal data will be removed and any information which needs to be kept (i.e. financial transactions) will be anonymised.
16. Right to restriction of processing
You can block the processing of your personal data. This means we may be able to store it, but cannot process it further without consent. Restricting data is required where the accuracy of data is challenged - but only until the accuracy has been verified.
17. The right to object
You have a right to object to the processing of your data. We must stop processing unless we can demonstrate a legal ground for the processing.
18. How we deal with personal data internally
18.1 We will:
- train our employees in relation to our responsibilities under the GDPR Rules
- ensure that only appropriately trained, supervised and authorised personal have access to personal data held by us; and
- regularly evaluate and review our collection and processing of personal data and the performance of employees and third parties working on our behalf to ensure that it is in accordance with the GDPR Rules.
18.2 We will keep internal records of personal data that we collect and process including, in relation to that personal data, details of the categories, any transfers, our security measures, our purpose of collection and the duration of retention of that personal data. We will also retain details of all third parties that either collect your personal data for us or that we use to process your personal data.
18.3 We will carry out privacy impact assessments as required by law.
19. Transferring personal data to a country outside the EEA
We may transfer personal data to countries outside of the EEA however we will ensure that the transfer is:
- to a place that the EU has judged to provide adequate levels of protection for personal data
- to a place that provides adequate safeguards under either an agreement with a public body, rules that bind companies or standard data protection clauses adopted by the EU or some other form of approved code of conduct approved by a supervisory authority or certification or other contractual clauses or regulatory provisions
- necessary for the performance of a contract between you and us or with a view to creating that contract
- made with your consent
- necessary for important public interest reasons, legal claims, to protect your vital interests
20. Notification of personal data security breach
20.1 If a personal data security breach occurs, we will manage and respond to it effectively in accordance with GDPR and it must be reported immediately to our Data Protection Lead.
20.2 We will notify the Information Commissioners Office (ICO) and any data subject of personal data security breaches to the extent we are required to do so by GDPR.
20.3 If disclosure is not required by GDPR, we will nevertheless investigate closely all the circumstances surrounding the breach and examine the seriousness of the breach and the benefits that might be obtained by disclosure (such as limiting risks of fraud) and we will give careful consideration to any decision to notify the ICO or you, especially if your rights and freedoms as data subjects are affected.
This policy was last updated May 2018.