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Data protection principles
Jalon Valley Help will follow the data protection principles, guided by information from the Spanish Data Protection Authority AEPD and the Regulations specified in The Reglamento General de Proteccion de Datos 1.
Lawfulness, fairness and transparency; Personal data should be processed lawfully, the lawful basis for use is consent by the individual. We only collect the data we need to manage and communicate with the membership, and we demonstrate how we collect this and what we do with it.
Purpose limitation; Personal data should be collected solely for specified, explicit and legitimate purposes defined as membership administration, communicating with members about JVH events and activities, membership updates or issues.
Data minimisation; Personal data should be adequate, relevant and limited to what is necessary. This is the minimum data required to carry out membership administration and to enable email contact with JVH members.
Accuracy; Personal data stored and managed should be accurate and, where necessary, kept up to date. Member’s data is renewed annually as part of the membership renewal process. Members can request to see, update, or remove their data at any time.
Storage limitation; Personal data should be kept no longer than is necessary for the purposes for which the personal data are processed. Member’s data is removed and deleted on lapse of membership after a period of grace and in any case at 12 months, or when instructed by a member.
Integrity and confidentiality; Personal data should be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
INDIVIDUAL MEMBERS RIGHTS UNDER GDPR
JVH will ensure that members’ information is managed in such a way as to not infringe an individual member’s rights which include:
• The right to be informed – what data is held by JVH.
• The right of access – entitled to have access to your data held by JVH.
• The right to rectification – amend or correct the data held by JVH.
• The right to erasure – to remove, delete all reference, i.e. be forgotten.
• The right to restrict processing – to limit some aspects of how data is used.
• The right to data portability – to be able to forward data to another.
• The right to object – to question current use and / or seek resolution.
SUBJECT ACCESS REQUEST
JVH members are entitled to request access to the information and / or to instruct JVH to comply with a member’s instructions with regarding their data that is held by JVH. A ‘subject access request’ can be made with regard to the individual member rights above, at any time to the Secretary in writing. These should be to The Secretary at Jalon Valley Help, Apartado Correos 14, 03727 Xaló.
JVH will establish that the request is authentic, it will be formally acknowledged and deal with it within 14 days. The Regulation also allows provision for exceptional circumstances or a potential charge for multiple applications.
Photographs are classified as personal data. Any person can object and request at any time to have a displayed photograph removed providing JVH can verify the request is authentic and relates to the individual.
ACCOUNTABILITY AND GOVERNANCE
The GDPR requires that JVH demonstrate that it complies with the data protection principles set out previously and respect the rights of the individual.
Implement appropriate technical and organisational measures that ensure and demonstrate that JVH complies with its data protection obligations. Maintain internal Data Protection and Privacy Policies, ongoing staff awareness and routine testing to ensure that these measures are effective.
Document the relevant JVH processes to instruct and demonstrate correct method of carrying out procedures.
Future improvements and new work must incorporate data protection and privacy principles.
JVH recognises the role of “Data Controller” as the JVH Committee, that is, the entity that decides the purpose and manner that personal data is used. The role of “Data Processor” is also confined to Committee staff and appointed JVH members who carry out processing of personal data on behalf of the “Data Controller”.
DATA BREACH NOTIFICATION
If a data breach occurs, action shall be taken to minimise the harm by ensuring all Committee Members are aware that a breach has taken place and take steps to identify how the breach has occurred. The Committee shall then seek to rectify the cause of the breach as soon as possible to prevent any further breaches.
The Committee shall also contact the relevant JVH members to inform them of the data breach and actions taken to resolve the breach. The Committee shall also notify the relevant authorities if the breach is a notifiable event as described under the Regulations.
A FINAL NOTE
The guidance states this Law is both new and complex across the EU. The Authorities are expecting to see a steady move towards compliance. This policy will be reviewed on a regular basis. If you see any item that you would like further clarification or information on please contact, in the first instance, the Secretary here.
This policy was last updated: February 2019 Next review date for this item: March 2021
This policy should be read along with JVH's Data Protection Policy.
How The Information Is Gathered If you join JVH you will be asked to provide certain information by completing the application form, and later, via renewal, or change of detail forms.
THE PERSONAL INFORMATION WE COLLECT
• Email address
• Telephone number (Home and Mobile as appropriate)
• Town and Spanish postcode
• Consent to use your Data for membership admin
• Consent to use your email address regarding JVH news & activities
In addition to the application form we will assign the following:-
• Membership number
• Join and renewal Dates
HOW DO WE USE THE INFORMATION WE COLLECT?
To manage membership administration and planning of our JVH. To communicate with you about our news and events.
WHO DO WE SHARE YOU PERSONAL INFORMATION WITH?
We do not share your data with any other organisation
HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?
While you are a member your information is kept on record and stored securely. After you leave or your membership expires all your membership information will be removed after a period of grace. In all instances this will be no longer than 12 months. References in Newsletters, photographs of events etc. are not part of this process. As part of your data protection rights i.e. “the right to be forgotten”, we can remove your data at your request. Your rights, including Subject Access Request. You have the right to ask us, in writing or via email, for a copy of the personal data held about you. You can request to delete, amend or modify your data, including consent preferences at any time. We will take care to verify your identity and respond to your request within 14 days. Members can make this request in writing to The Secretary at Jalon Valley Help, Apartado Correos 14, 03727, Xaló, Alicante. Members can change personal information via the Change of Details Form available at the above address. Further information regarding this can be found in JVH's Data Protection Policy.
A FINAL NOTE.
This Policy will be reviewed on a regular basis. If you see any item that you would like further clarification or information on please contact, in the first instance, The Secretary.
This policy was last updated: March 2019 Next review date for this item: February 2021