The Data Controller of the information being collected is:
The Craig Lodge Trust.
Craig Lodge, Dalmally, Argyll and Bute, PA33 1AR
Phone: 01838 200696.
For any queries or concerns about how your personal data is being processed you can contact the relevant Data Protection Officer at firstname.lastname@example.org.
This privacy statement relates to the following process:
Use of personal data supplied by individuals for filming, photographic, sound recording.
We will use your information to:
Ensure that we have your written consent to use film, photo, sound recording and text that we have created featuring you or that you have provided
Contact you to update your permission (if applicable).
The legal basis on which we use your personal data is consent.
We will not share your data with any other party.
Special category (sensitive) data
We do not collect sensitive data.
Your personal data will be retained after the completion of your signed Filming, photographic, sound recording and text release form for no longer than 5 years, unless within that 5 year period we gain your permission to hold and use your data for longer.
Your rights and preferences
The following rights are rights of data subjects:
- The right to access your personal data
- The right to rectification if the personal data we hold about you is incorrect
- The right to restrict processing of your personal data
The following rights apply only in certain circumstances:
- The right to withdraw consent at any time if consent is our lawful basis for processing your data
- The right to object to our processing of your personal data
- The right to request erasure (deletion) of your personal data
- The right to data portability
You also have the right to lodge a complaint with the Information Commissioner’s Office about our handling of your data.
Charity means Craig Lodge Trust, a registered charity.
GDPR means the General Data Protection Regulation.
Responsible Person means Ken Black email@example.com
Register of Systems means a register of all systems or contexts in which personal data is processed by the Charity.
1. Data protection principles
The Charity 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
This policy applies to all personal data processed by the Charity. The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy. This policy shall be reviewed at least annually. The Charity 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 Charity 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 charity 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 Charity 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 Charity’s systems.
5. Data minimisation
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. [Add considerations relevant to the Charity’s particular systems]6. AccuracyThe Charity 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. [Add considerations relevant to the Charity’s particular systems]
7. Archiving / removal
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 process annually. The archiving policy shall consider what data should/must be retained, for how long, and why.
The Charity 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 back-up 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 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).