Data Protection and Privacy Policy
The Suffolk Military Show is fully committed to compliance with the requirements of Data Protection legislation. The Suffolk Military Show followed the prescriptions of the Data Protection Act 1998 (“the Act”),
which came into force on the 1 March 2000 and has adjusted their policies to reflect the new General Data Protection Regulations, with effect from 25 May 2018. The Suffolk Military Show will therefore follow
procedures that aim to ensure that all employees, contractors, agents, consultants, partners or other servants of the Event who have access to any personal data held by or on behalf of the Suffolk Military Show, are fully
aware of and abide by their duties and responsibilities under this legislation.
Introduction
This policy is provided by The Suffolk Military Show who is the data controller for your data.
We hold personal data about our employees, residents, suppliers and other individuals for a variety of purposes.
This policy sets out how we seek to protect personal data and ensure that our administrators understand the rules governing their use of personal data to which they have access in the course of their
work.
Business Purposes
The purposes for which personal data may be used by us:
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Personnel, administrative, financial, statutory and legislative purposes, consultations and business development purposes;
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Purposes include the following:
- Compliance with our legal, regulatory and governance obligations and good practice;
- Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests;
- Ensuring policies are adhered to (such as policies covering email and internet use);
- Operational reasons, such as training and quality control, ensuring the confidentiality of sensitive information, security vetting and checking;
- Investigating complaints;
- Checking references, ensuring safe working practices, monitoring and managing access to systems and facilities, administration and assessments;
- Monitoring conduct, disciplinary matters;
- Improving services
Personal Data
Information relating to identifiable individuals.
Personal data we gather may include:
Names, titles and aliases, photographs, contact details such as telephone numbers,
addresses and email addresses, financial detail.
Sensitive Data
No data held
Scope
This policy applies to all Managerial members of the Suffolk Military Show Team who are familiar with this policy and comply with its terms.
This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be
circulated prior to being adopted. The known key administrator will oversee this process.
Our procedures
Fair and lawful processing.
We must process personal data fairly and lawfully in accordance with individual’s rights. This generally means that we should not process personal data unless the individual whose details we are processing has consented
to this happening.
Responsibilities of IT support
- Ensure all systems, services, software and equipment are in line with The Suffolk Military Show Risk Assessment Schedule;
- Checking and scanning security hardware and software regularly to ensure it is functioning properly;
- Researching third-party services, such as cloud services that may be used to store or process data.
Responsibilities of the Officers
- Approving data protection statements attached to emails and other marketing companies;
- Addressing data protection queries from clients, target audiences or media outlets;
- Ensure all marketing initiatives adhere to data protection laws.
- Keeping updated about data protection, responsibilities risks and issues;
- Reviewing all data protection procedures and policies on a regular basis;
- Assisting with data protection training and advice;
- Answering questions on data protection;
- Responding to individuals such as members of the public, service users and employees who wish to know which data is being held on them;
The processing of all data must be:
- Necessary to deliver our services;
- In our legitimate interests and not unduly prejudice the individual’s privacy;
- In most cases this provision will apply to routine business data processing activities.
Personal Data may be used for some or all of the following purposes:
- To confirm your identity to provide some services;
- To contact you by post, email, telephone or using social media;
- To help us build a picture of how we are performing;
- To prevent and detect fraud and corruption in the use of public funds and where necessary for the law enforcement functions;
- To enable us to meet all legal and statutory obligations and powers including any delegated functions;;
- To maintain our own accounts and records;
- To seek your views, opinions or comments;
- To notify you of changes to our facilities, services and events;
- To send you communications you have requested and that may be of interest to you;
- To process relevant financial transactions;
- To allow the statistical analysis of data so we can plan the provision of services;
Our processing may also include the use of CCTV systems for the prevention and prosecution of crime.
Our Terms of Business contains a Privacy Notice relating to Data Protection. The notice:
- Sets out the purpose for which we hold personal data on our customers;
- Highlights that our work may require us to give information to third parties such as expert witnesses Provides that service users and correspondents have a right of access to the personal data that we hold about them.
Accuracy and relevance
We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purposes for which it was obtained. We will not process personal data obtained for one purpose for any
unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.
Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed.
Your personal data
Reasonable steps must be taken to ensure that personal data we hold about you is accurate and updated as required. For example, if your personal circumstance change, please inform the key administrator so that your
records can be updated.
Data security
Personal data will be kept secure against loss or misuse.
Storing data securely:
- In cases when data is stored on printed paper, it will be kept in a secure place where unauthorised personnel cannot access it;
- Printed data will be shredded when it is no longer needed;
- Data stored on a computer should be protected by strong passwords that are changed regularly. The Key Administrator is encouraged to use a password manager to create and store their passwords;
- Data stored on CDs or memory sticks will be locked away securely when they are not being used;
- The Suffolk Military Show currently does not use 365 to store data on the cloud;
- Servers containing personal data will be kept in a secure location, away from the general office space;
- Data will be regularly backed up in line with the backup procedures;
- Data will not be saved directly to mobile devices such as laptops, tablets or smartphones;
- All servers containing sensitive data must be approved and protected by security software and strong firewall.
Data retention:
We must retain personal data for no longer than is necessary. What it necessary will depend on the circumstances of each case, taking into account the reasons that the personal data was obtained, but should
be determined in a manner consistent with Retention Policy.
Subject access requests:
Under the Data Protection Act 2018, individuals are entitled, subject to certain exceptions, to request access to information held about them. If a subject access request is received, this will be referred to the Key
Administrator.
Processing information in accordance with an individual’s rights
Any request by an individual not to use their personal data for direct marketing purposes will be abided by and the Key Administrator will be notified immediately.
Direct marketing material must not be sent by email unless there is an existing business relationship with them in relation to the services being marketed.
The Suffolk Military Show will only use data for the purpose of its immediate business.
Training:
The Key Administrator will receive training on this policy. Training will be provided at least every two years or whenever there is a substantial change in the law or our policy and procedure. Training will be provided in-
house when needed.
It will cover:
- The law relating to data protection;
- Our data protection and related policies and procedures.
Privacy Notice – transparency of data protection
Being transparent and providing accessible information to individuals about how we will use their personal data is important. The following are details on how we collect data and what we will do with it:
Conditions for processing
We will ensure any use of personal data is justified using at least one of the conditions for processing and this will be specifically documented. The Key Administrator is responsible for processing personal
data will be aware of the conditions for processing. The conditions for processing will be available to data subjects in the form of a privacy notice.
Justification for personal data
We will process personal data in compliance with all seven data protection principles:
- Lawfulness, fairness and transparency
- Purpose limitation
- Data minimisation
- Accuracy
- Storage limitation
- Integrity and confidentiality
- Accountability
We will document the additional justification for the processing of sensitive data and will ensure any biometric and genetic data is considered sensitive.
Consent
The data that we collect is subject to active consent by the data subject. This consent can be revoked at any time.
Criminal record checks
Criminal record checks are not within the remit and cannot be undertaken.
Data portability
Upon request, a data subject should have the right to receive a copy of their data in a structured format. These requests should be processed within one month, provided there is no undue burden
and it does not compromise the privacy of other individuals.
A data subject may also request that their data is transferred directly to another system. This must be done for free.
A data subject may request that any information held on them is deleted or removed and any third parties who process or use that data must also comply with the request. An erasure request can only
be refused if an exemption applies.
Privacy by design and default:
Privacy by design is an approach to projects that promote privacy and data protection compliance.
International data transfers:
No data may be transferred outside of the EEA without first discussing it with the Key Administrator.
Specific consent from the data subject must be obtained prior to transferring their data outside the
EEA.
Data audit and register:
Regular data audits to manage and mitigate risks will inform the data register. This contains information on what data is held, where it is stored, how it is used, who is responsible and any further regulations or retention timescales that may be relevant.
Reporting breaches:
All members of the team have an obligation to report actual or potential data protection compliance failures. This allows us to:
- Investigate the failure and take remedial steps if necessary;
- Maintain a register of compliance failures;
- Notify the Supervisory Authority (SA) of any compliance failures that are material either in their own rights or as part of a pattern of failures.
Monitoring
Everyone must observe this policy. The Key Administrator has overall responsibility for this policy and will monitor it regularly to make sure it is being adhered to.
Compliance:
It is extremely important that everyone holding data in relation to the operations of The Suffolk Military Show complies with this policy.
Further Processing:
If the Suffolk Military Show wishes to use personal data for a new purpose, not covered by this Privacy Notice, then we will provide a new notice, explaining the new use prior to commencing the processing
and setting out the relevant purpose and processing conditions. Where and whenever necessary, The Suffolk Military Show will seek prior consent to the new processing.
Changes to this notice:
The Suffolk Military Show will keep this Privacy Notice under regular review and will place any updated notice on The Suffolk Military Show webpage.
Contact details
Please contact us if you have any questions about this Privacy Policy or the personal data we hold about you or to exercise all relevant rights, queries or complaints:
info@suffolkmilitaryshow.co.uk