Data Protection Policy

Data Protection Policy

1) Policy statement

Social Sense is committed to a policy of protecting the rights and privacy of service users, external partners, volunteers staff and others in accordance with The Data Protection Act 1998. The policy applies to all internal and external members of staff and contracted practitioners. Any breach of The Data Protection Act 1998 or The Community Centre Data Protection Policy is an offence and in that event, disciplinary procedures apply.

As a matter of good practice, other organisations and individuals working with Social Sense, and who have access to personal information, will be expected to have read and comply with this policy. It is expected that any staff who deal with external organisations will take responsibility for ensuring that such organisations sign a contract agreeing to abide by this policy.

2) Scope of the policy

Personal information is any information that relates to a living individual who can be identified from the information. This includes any expression of opinion about an individual and intentions towards an individual. It also applies to personal data held visually in photographs or video clips (including CCTV) or as sound recordings.

Social Sense collects a large amount of personal data every year including: staff records, names and addresses of those requesting information, market and competitor data, as well as the many different types of primary research data collected via our programmes. In addition, it may be required by law to collect and use certain types of information to comply with statutory obligations of Local Authorities (LAs), government agencies and other bodies.

3) Legal Requirements

Data are protected by the Data Protection Act 1998, which came into effect on 1 March 2000. Its purpose is to protect the rights and privacy of individuals and to ensure that personal data are not processed without their knowledge, and, wherever possible, is processed without their consent.

The Act requires us to register the fact that we hold personal data and to acknowledge the right of ‘subject access’ – All service users, partner agencies, staff and stakeholders must have the right to copies of their own data.

4) Data Protection Principles

In terms of the Data Protection Act 1998, we are the ‘data controller’, and as such determine the purpose for which, and the manner in which, any personal data are, or are to be, processed. We must ensure that we have:

4.1) Fairly and lawfully processed personal data – Social Sense will always put our logo on all paperwork, stating their intentions on processing the data and state if, and to whom, we intend to give the personal data. Also provide an indication of the duration the data will be kept.

4.2) Processed for limited purpose – We will not use data for a purpose other than those agreed by data subjects (service users, staff and others). If the data held by us are requested by external organisations for any reason, this will only be passed if data subjects (service users, staff and others) agree. Also, external organisations must state the purpose of processing, agree not to copy the data for further use and sign a contract agreeing to abide by The Data Protection Act 1998 and Social Sense’s Data Protection Policy.

4.3) Adequate, relevant and not excessive – We will monitor the data held for our purposes, ensuring we hold neither too much nor too little data in respect of the individuals about whom the data are held. If data given or obtained are excessive for such purpose, they will be immediately deleted or destroyed.

4.4) Accurate and up-to-date – We will provide our stakeholders (service users, staff, external partners, and others) with a copy of their data once a year for information and updating where relevant. All amendments will be made immediately and data no longer required will be deleted or destroyed. It is the responsibility of individuals and organisations to ensure the data held by us are accurate and up-to-date. Completion of an appropriate form (provided by us) will be taken as an indication that the data contained are accurate. Individuals should notify us of any changes, to enable personnel records to be updated accordingly. It is the responsibility of Social Sense to act upon notification of changes to data, amending them where relevant.

4.5) Not kept longer than necessary – We discourage the retention of data for longer than it is required. All personal data will be deleted or destroyed by us after the limited purpose has finished.

4.6) Processed in accordance with the individual’s rights – All individuals that Social Sense hold data on have the right to:

  • Be informed upon the request of all the information held about them within 40 days.
  • Prevent the processing of their data for the purpose of direct marketing.
  • Compensation if they can show that they have been caused damage by any
    contravention of the Act.
  • The removal and correction of any inaccurate data about them.

4.7) Secure – Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of data.

All Social Sense computers have a log in system and our Contact Database is password protected, which allow only authorised staff to access personal data. Passwords on all computers are changed frequently. All personal and financial data is kept in a locked filing cabinet and can only be accessed by the Managing Director or the Office Manager. When staff members are using the laptop computers out of the office care should always be taken to ensure that personal data on screen is not visible to strangers.

4.8) Not transferred to countries outside the European Economic Area, unless the country has adequate protection for the individual – Data must not be transferred to countries outside the European Economic Area without the explicit consent of the individual. Social Sense takes particular care to be aware of this when publishing information on the Internet, which can beaccessed from anywhere in the globe. This is because transfer includes placing data on a web site that can be accessed from outside the European Economic Area.

5) Responsibilities

5.1) Social Sense must:

  • Manage and process personal data properly
  • Protect the individual’s right to privacy
  • Provide an individual with access to all personal data held on them.

5.2) Social Sense has a legal responsibility to comply with the Act. Social Sense, as a corporate body, is named as the Data Controller under the Act.

Data Controllers are people or organisations who hold and use personal information. They decide how and why the information is used and have a responsibility to establish workplace practices and policies that are in line with the Act.

5.3) Gary Lovatt (Managing Director) is responsible at Social Sense for all members of staff, external staff, and contracted practitioners to adhere to the Data Protection Act 1998 and this internal policy.

5.3) Social Sense is required to ‘notify’ the Information Commissioner of the processing of personal data. This information will be included in a public register which is available on the Information Commissioner’s website at the following link : http://www.ico.gov.uk/what_we_cover/promoting_data_privacy/keeping_the_register.aspx

5.4) Every member of staff that holds personal information has to comply with the Act when managing that information.

5.5) Social Sense is committed to maintaining the eight principles at all times. This means that the school will:

  • Inform Data Subjects why they need their personal information, how they will use it and with whom it may be shared. This is known as a Privacy Notice.
  • Check the quality and accuracy of the information held.
  • Apply the records management policies and procedures to ensure that information is not
    held longer than is necessary.
  • Ensure that when information is authorised for disposal it is done appropriately.
  • Ensure appropriate security measures are in place to safeguard personal information whether that is held in paper files or on a computer system.
  • Only share personal information with others when it is necessary and legally appropriate to do so.
  • Set out clear procedures for responding to requests for access to personal information known as subject access in the Data Protection Act.
  • Train all staff so that they are aware of their responsibilities and of Social Sense’s relevant policies and procedures.

This policy will be updated as necessary to reflect best practice or amendments made to the Data Protection Act 1998.

Please follow this link to the ICO’s website (www.ico.gov.uk) which provides further detailed guidance on a range of topics including individuals’ rights, exemptions from the Act, dealing with subject access requests, how to handle requests from third parties for personal data to be disclosed etc.

For help or advice on any data protection or to request freedom of information, please do not hesitate to contact

Laura Cain
Office Manager
Tel: 0161 216 4080
Email: Laura@socialsense.co.uk

Last update: April 2017