Winchester u3a Data Protection Policy

This policy applies to the running of Winchester U3A. The policy sets out the requirements that we have to gather data for membership purposes. The policy details how data will be gathered, stored and managed in line with the General Data Protection Regulation (GDPR).

The policy is reviewed on a regular basis to ensure that we are compliant. This policy should be read in tandem with our Privacy Policy.
This data protection policy ensures that we:-

• Comply with data protection law and follow good practice.
• Protect the rights of members and partners.
• Are open about how we store and process members data.
• Protect ourselves from the risks of a data breach.

General guidelines for Committee members:-
• Access to data covered by this policy will be limited to those who need to contact or provide a service to our members.
• We will provide training to committee members and future committee members to help them understand their responsibilities when handling personal data.
• We will keep all data secure, by taking sensible precautions and following the guidelines below.
• Data will not be shared outside of our U3A unless with prior consent and/or for
• specific and agreed reasons.
• We will request help from Information Commissioners Office if we are unsure about any aspect of data protection.

The General Data Protection Regulation identifies 8 data protection principles.

Principle 1 - Personal data shall be processed lawfully, fairly and in a transparent manner.

Principle 2 - Personal data can only be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

Principle 3 - The collection of personal data must be adequate, relevant and limited to what is necessary.

Principle 4 – Personal data held should be accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data is correct and that any inaccurate data is erased or rectified without delay.

Principle 5 – Personal data that is kept in a form which permits identification of individuals shall not be kept for longer than is necessary.

Principle 6 - Personal data must be processed in accordance with the individual’s rights.

Principle 7 - Personal data must be processed in a manner that ensures appropriate security of the personal data against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Principle 8 - Personal data cannot be transferred to another country unless that country ensures an adequate level of protection for the rights of individuals in relation to the processing of personal data.

We request data from members so we can contact them about their involvement with our U3A. The forms used to request data contains a privacy statement as to why information is being requested and what it will be used for. Members will be asked to provide consent for their data to be held and a record of this consent and their data will be securely held.

Members can, at any time, remove their consent by contacting the Membership Secretary.

Once a member requests not to receive certain contact this will be acted upon promptly and reported to them.

Members will be told how we use their data. Appropriate use of member data will include:-

• Contacting members about our events and activities
• Contacting members about specific issues that may have arisen during the course of their membership.

We will ensure inappropriate contact is not made to our members, such as, marketing and/or promotional materials from external service providers.

We will ensure that use of members' data does not infringe their rights which include:-

• The right to be informed.
• The right of access.
• The right to rectification.
• The right to erasure.
• The right to restrict processing.
• The right to data portability.
• The right to object.

Members will only be asked to provide data that is relevant for membership purposes. This will include:-

• Name.
• Postal address.
• Email address.
• Telephone number.

Any further data will be obtained with the specific consent of the member, who will be informed as to why this data is required. Any such data will be deleted once that event has taken place, unless it was required – with agreement – for a longer period.

Where a members' data needs to be shared with a third party, due to an accident or incident involving statutory authorities, then consent does not have to be sought from the member.

We have a responsibility to ensure members' data is kept up to date. Members will be asked to let the Membership Secretary know if any of their data changes.

We will ensure that we are compliant with data protection requirements and can prove it.

Members will be asked to provide consent, which will be securely held as evidence of compliance. We will review data protection and what data is held and who has access to it on an annual basis. At the beginning of August, the Treasurer will notify the other committee members of any individuals who are no longer a U3a member.

The Committee have contracted for services from with the following 3rd party data processors:-

• Company that provides website services
• Printer to print our Newsletter
• Company who oversee the distribution of the Third Age Matters magazine

The committee has scrutinised their Terms and Conditions and is satisfied that they are GDPR compliant.

Members can request access to the data we hold on them by contacting the Membership Secretary who will normally deal with a request within 14 days. A record will be kept of the date of the request and the date of the response.

Where a data breach has occurred action will be taken to minimise the harm. We will then seek to rectify the cause of the breach as soon as possible. We will contact the Information Commissioners Office within 72 hours of the breach being reported. We will contact the relevant members to inform them of the data breach and the actions we have taken to resolve it.

If a member contacts us feeling that there has been a breach, they will be asked to produce an email or a letter detailing their concern. We will then investigate the breach. The member will also be informed that they can report their concerns to the Information Commissioners Office. Breach matters will be subject to a full investigation, records will be kept and all those involved notified of the outcome.

Policy last reviewed September 2023