Privacy Policy The Norwich Society
Last updated 15.05.2018

Definitions
Charity means: The Norwich Society, a civic Society and registered charity. Registration number: 311118
GDPR means: the General Data Protection Regulation.
Responsible Person means: the Charity’s Coordinator who is responsible for maintaining the data protection policy and the data processor.
Register of Systems means: a register of all data contexts in which personal data is processed by the Charity.

1. Data protection principles
The Norwich Society is committed to processing data in accordance with its responsibilities under the GDPR. Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. 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;
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d. 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;
e. 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
f. 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
a. This policy applies to all personal data processed by the Charity.
b. The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy.
c. This policy shall be reviewed by the Charity’s Executive Committee at least annually.
d. The Charity shall register with the Information Commissioner’s Office as an organisation that processes personal data.

3. Lawful, fair and transparent processing
a. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.
b. The Register of Systems shall be reviewed by the Charity’s Executive Committee at least annually.
c. 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
a. All data processed by the charity must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interest. In accordance with that law, the Charity processes personal data as described above because it is:
1) Necessary for the performance of our membership contracts with our members: and/or
2) Necessary for the purposes of the Charity’s legitimate interests, namely to fulfil its function as a Civic Charity in accordance with applicable law and regulations and to conduct and manage our relationship with specific individuals. Where we use your personal data, we make sure that we take into account any potential impact that such use may have on you. If we believe your interests or fundamental rights and freedoms override our legitimate interests then we won’t use your personal data on this basis and may seek your specific consent.
3) Necessary for compliance with its legal obligations b. The Charity shall note the appropriate lawful basis in the Register of Systems. c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data. d. 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 Charity’s systems.

5. Data minimisation
a. The Charity shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
b. The Charity maintains a Members Database comprising the following information which may contain personal data: Personal/contact information: names (including pseudonyms), contact (including phone numbers and emails where provided) and address details. Payment information: bank details (For those paying by Direct Debit for membership) if we can collect gift aid on subscription Correspondence: Communication method preference Other: any other information you choose to provide to us.
c. In addition to the Members Database, the Charity also maintains separate data comprising information (including name, address, contact details and business employer) provided by individuals from related organisations, suppliers, interested parties and other contacts. The Norwich Society is committed to fair and transparent processing and any individual requiring information as to where we gained his/her personal data and may contact the Charity at any time.

6. Accuracy, Archiving / removal
a. The Charity shall take reasonable steps to ensure personal data is accurate.
b. 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.
c. To ensure that personal data is kept for no longer than necessary, the Charity shall put in place an archiving policy for each area in which personal data is processed and review this policy annually.
d. The archiving policy shall consider what data should/must be retained, for how long, and why.
e. You have the right to ask the Charity to limit or cease processing or erase information we hold about you. In responding to such requests, the Charity will communicate to the individual concerned the impact of such restrictions or deletions, for example, the Charity’s ability to process and manage the individual’s membership.
f. The Charity takes reasonable steps to ensure that the personal data it holds about you is accurate and up-to-date and we will comply with any requests to rectify any inaccurate data we may hold about you.
g. The Norwich Society relies on the accuracy of information provided by its members and will rectify any notified inaccuracies following a request by the individual concerned. Requests for access to information regarding personal, financial and works information should be made in writing to The Norwich Society, Theatre Street, Norwich, NR2 1RQ via email to admin@thenorwichsociety.org.uk or by phone 01603 765606.

7. Security
a. The Charity shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
b. 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.
c. When personal data is deleted this should be done safely such that the data is irrecoverable. d. Appropriate back-up and disaster recovery solutions shall be in place.

8. Breach
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 Charity 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).

END OF POLICY