Company Registration: 08971619
Last updated: 16th Day of April 2018
Company means My Live School CIC.
GDPR means the General Data Protection Regulation.
Responsible Person means the nominated GDP officer Chris Thomas.
Register of Systems means a register of all systems or contexts in which personal data is processed.
1. Data protection principles
The company is committed to processing data in accordance with its responsibilities under the 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 for 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 company. The Responsible Person shall take responsibility for the ongoing compliance with this policy. This policy shall be reviewed at least annually. The community interest company shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
To ensure its processing of data is lawful, fair and transparent, the community interest company shall maintain a Register of Systems. The Register of Systems shall be reviewed at least annually.
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.
4. Lawful purposes
All data processed by the company 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 company shall note the appropriate lawful basis in the Register of Systems. 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 should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the community interest company systems.
5. Data minimisation
The company shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. Personal data collected above what is necessary can only be retained when strictly relevant to planned developmental areas of the community interest company. Personal data retained past four years will be subject to an archiving system (7b). The company should review the Registrar of Systems and ensure third-party GDPR compliance annually. The company should only use third-party systems when deemed necessary and relevant within the processing principles of GDPR.
The company shall 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. In the absence of automation, the responsible person should review and verify data across the community interest company systems.
7. Archiving / removal
To ensure that personal data is kept for no longer than necessary, the community interest company shall put in place an archiving policy for each area in which personal data is processed and review this process annually. The archiving policy shall consider what data should/must be retained, for how long, and why.
The company 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 who need access and appropriate security should be in place to avoid unauthorised sharing of information. When personal data is deleted this should be done safely such that the data is irrecoverable. Appropriate backup and disaster recovery solutions shall be in place.
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 community interest company 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).
10. Register of Systems
Trusted third party products are used to fulfil system and security needs. Each component is governed by their own policy and procedures. The system components outsourced by the community interest company and compliant with GDPR are;
Google.UK Ltd: G suite ‘for business’ products and applications including desktop and mobile cloud synchronisation: Full name, Email address and written conversations, Telephone, Company Address, Processing notes, Appointments, Contact history, G+ Social Links, Audio and Video Chat history, Session and cross-session website behaviour logs.
Agile (CRM) Ltd: Full name, Email address, Email conversations, Telephone, Company Address, Processing Notes, Appointments, Contact history, Social media URL user links, Subscription status, Session and cross-session website behaviour logs.
Invoice Simple Ltd: Software applications including remote browser access: Full name, Email address, Email conversations, Telephone, Company Address, Processing Notes, Ref transaction history.
Stripe UK Ltd: Electronic payment processing: Ref transaction history, ‘Opt-in’ Credit/Debit card information.
Lloyds Bank PLC: Branch/Online banking and BACS payment processing: Ref transaction history.
Website server: Full name, Email address, Telephone, Company Address, Subscription status, IP browser logs, Session and cross-session behaviour logs.
Data encrypted backup server/s and local hard drives: All mentioned.
Streaming servers: IP access logs listener and source.