Data Protection Policy

Sussex Family History Group

Registered Charity No 273726

Definitions

1. Data protection principles

The Sussex Family History Group (SFHG) is committed to processing data in accordance with its responsibilities under the UK GDPR, Data Protection Act 2018, Data (Use and Access) Act 2025 and all other current data protection and security legislation

The legislation requires that personal data shall be:

1. processed lawfully, fairly and in a transparent manner in relation to individuals; (lawfulness, fairness and transparency)

2. collected (whether from the data subject or otherwise) for specified, explicit and legitimate purposes and not further processed by or on behalf of a controller in a manner that is incompatible with the purposes for which the controller collected the data (purpose limitation)

3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed; (data minimisation)

4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay; (accuracy)

5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; (storage limitation) and

6. 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.” (integrity and confidentiality)

2. General provisions

1. This policy applies to all personal data processed by the SFHG.

1. The Responsible Person shall take responsibility for the SFHG’s ongoing compliance with this policy. (accountability)

1.  For the avoidance of doubt, processing is not lawful by virtue only of being processing that is compatible with the purposes for which the personal data was collected

1. This policy shall be reviewed at least bi-annually.

3. Lawful, fair and transparent processing and Purpose Limitation

1. To ensure its processing of data is lawful, fair and transparent, the SFHG shall maintain a Register of Systems which is reviewed regularly Where consent is relied upon as a lawful basis for processing data, evidence of opt-in -consent shall be kept with the personal data and noted in the register.

b.     All data processed by the charity must be done on one of the following lawful bases: consent for a specific purpose, contract, legal obligation, protection of vital interests, public task or legitimate interests (see ICO guidance for more information).

1. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the SFHG’s systems. 

2. Further processing of data, other than the purpose for which SFHG collected the data must take into account (amongst other considerations) links to the original purpose, the nature and consequences of further processing and whether further consent should be obtained.

3. Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner.

5. Data minimisation

1. The SFHG shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

1. SFHG officers and Committee members will have access to information held only inrelation to their role and on a limited ‘need to know’ basis.

6. Accuracy

1. The SFHG shall take reasonable steps to ensure personal data is accurate.

1. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

1. Membership is renewed annually and renewing members are asked to check and reconfirm their details.

2. Members have the right to request corrections to their personal data

7. Subject Access and Archiving / removal

1. To ensure that personal data is kept for no longer than necessary, the SFHG shall put in place an archiving plan for each area in which personal data is processed and will review this process regularly.

1. The archiving plan shall consider what data should/must be retained, for how long, and why.

2. Individuals have the right to access their personal data and any such requests made to SFHG shall be dealt with in a timely manner (one month).  This right includes being informed of the purposes for processing data, the categories of personal data held and information on who the data has been or will be disclosed to.

8. Security

1. The SFHG shall ensure that personal data is stored securely using modern software that is kept-up-to-date. 

1. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.

1. When personal data is deleted this should be done safely such that the data is irrecoverable.

1. Appropriate back-up and disaster recovery solutions shall be in place.

9. Complaints and Breaches of security

Individuals have the right to complain about the processing of their data. If you object you should do so in writing to the Secretary stating your reasons and SFHG have 21 days to respond.  

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the SFHG shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).

Review Date July 2028