1. Data protection principles
The East Suffolk Lines Community Rail Partnership (ESLCRP) is committed to processing data in accordance with its responsibilities under the General Data Protection Regulation (GDPR).
Article 5 of the GDPR requires that personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- 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;
- 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; and
- 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.
2. General provisions
- This policy applies to all personal data processed by the ESLCRP
- The Responsible Person shall take responsibility for ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
3. Lawful, fair and transparent processing
- To ensure its processing of data is lawful, fair and transparent, the ESLCRP shall maintain a register.
- The register shall be reviewed at least annually.
- Individuals have the right to access their personal data and any such requests made to the ESLCRP shall be dealt with in a timely manner.
4. Lawful purposes
- All data processed by the ESLCRP must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
- The ESLCRP shall note the appropriate lawful basis in the register.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent will be clearly available and systems are in place to ensure such revocation.
5. Data minimisation
- The ESLCRP will ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- The ESLCRP will take reasonable steps to ensure personal data is accurate.
- 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.
- The ESLCRP will shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
- Access to personal data shall be limited to personnel within the ESLCRP who need access and appropriate security is in place to prevent unauthorised sharing of information.
- When personal data is deleted this should be done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions shall be in place.