Introduction
The Association of Chaplaincy in General Practice (“ACGP”) needs to collect and use certain types of information about the individuals who come into contact with ACGP in order to carry on our work. This personal information must be collected and dealt with appropriately whether it is collected on paper, stored in a computer database, or recorded on other material and there are safeguards to ensure this under data protection legislation (Data Protection Act 2018 and any superseding legislation relating to data security and protection).
Data Controller
ACGP’s Company Secretary is the Data Controller under the Act, which means that they determine what purposes personal information will be used for. They are also responsible, where appropriate, for notifying the Information Commissioner of the data ACGP holds or is likely to hold, and the general purposes that this data will be used for.
Disclosure
ACGP will not share data with other agencies.
Registration
ACGP is registered with the Information Commissioner’s Office with the registration number ZB572012.
Compliance
ACGP regards the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal. It intends to ensure that personal information is treated lawfully and correctly.
To this end, ACGP will adhere to the Principles of Data Protection, as detailed in the Act. Specifically, these Principles require that personal information:
- shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met;
- shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes;
- shall be adequate, relevant and not excessive in relation to those purpose(s);
- shall be accurate and, where necessary, kept up to date;
- shall not be kept for longer than is necessary;
- shall be processed in accordance with the rights of data subjects under the Act;
- shall be kept secure by the Data Controller who takes appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal information;
- 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 Individuals/Service Users in relation to the processing of personal information.
- observe fully conditions regarding the fair collection and use of information;
- meet its legal obligations to specify the purposes for which information is used;
- collect and process appropriate information, and only to the extent that it is needed to fulfill its operational needs or to comply with any legal requirements;
- ensure the quality of information used;
- ensure that the rights of people about whom information is held can be fully exercised under the Act. These include:
- the right to be informed that processing is being undertaken;
- the right of access to one’s personal information;
- the right to prevent processing in certain circumstances; and
- the right to correct, rectify, block or erase information which is regarded as wrong information).
- take appropriate technical and organisational security measures to safeguard personal information;
- ensure that personal information is not transferred abroad without suitable safeguards;
- treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information;
- set out clear procedures for responding to requests for information.
Information and records relating to individuals will be stored securely and will only be accessible to authorised staff. (For the purposes of this document, staff is deemed to include trustees, contracted employees, full- or part-time volunteers, and any other people representing ACGP at an event or as part of a programme). Information will be stored for only as long as it is needed or required by statute and will be disposed of appropriately. Records of contact with clients will be kept for six years after the end of the last year in which we had contact with them as a client. It is ACGP’s responsibility to ensure all personal data is non-recoverable from any computer system previously used within the organisation, which has been passed on/sold to a third party.
Data access and accuracy
All individuals have the right to access the information ACGP holds about them. ACGP will also take reasonable steps to ensure that this information is kept up to date by asking data subjects whether there have been any changes.
In addition, ACGP will ensure that:
- it has a Data Protection Officer with specific responsibility for ensuring compliance with Data Protection;
- everyone processing personal information understands that they are contractually responsible for following good data protection practice;
- everyone processing personal information is appropriately trained to do so and is appropriately supervised;
- anybody wanting to make enquiries about handling personal information knows what to do;
- it deals promptly and courteously with any enquiries about handling personal information;
- it describes clearly how it handles personal information;
- it will regularly review and audit the ways it holds, manages and uses personal information;
- it regularly assesses and evaluates its methods and performance in relation to handling personal information;
- all staff are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them.
