City of Winchester Trust
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City of Winchester Trust Data Protection Policy

This policy applies to the running of City of Winchester Trust. The policy applies to the gathering of data on members, employees, volunteers and trustees (collectively called 'stakeholders'). The policy details how data will be gathered, stored and managed in line with the General Data Protection Regulation (GDPR). The policy will be reviewed on a regular basis to ensure that the Trust is compliant. This policy should be read in tandem with the Trust Privacy Policy.

This data protection policy ensures that the Trust:



The General Data Protection Regulation identifies 8 data protection principles and the Trust will comply with all these eight data protection principles.

We request data from stakeholders so we can contact them about their involvement with our Trust. The forms used to request data contain a privacy statement as to why information is being requested and what it will be used for. Stakeholders will be asked to provide consent for their data to be held and a record of this consent and their data will be securely held. Stakeholders can, at any time, remove their consent by contacting the Membership Secretary. Once a Stakeholder requests the Trust not to contact that person this will be acted upon promptly and comnfirmed by the Trust by email, telephone or post.


Stakeholders will be told for what we use their data. Appropriate use of stakeholders data will include:

The Trust will not pass the details held about stakeholders to other organisations without their consent.

We will ensure that use of stakeholders' data does not infringe their rights which include:

Stakeholders will only be asked to provide data that is relevant for membership/employee/volunteering purposes. This will include:

Any further data will be obtained with the specific consent of the stakeholder who will be informed as to why this data is required. Data will be destroyed when no longer required for the purposes for which it was acquired.

Where a stakeholders' data is required by law to be shared with a third party involving statutory authorities then consent does not have to be sought from the stakeholder.

The Trust will endeavour to keep stakeholders' data up to date. Stakeholders will be asked to let the Trust know if any of their data changes.

We will ensure that we are compliant with data protection requirements and can prove it. Stakeholders will be asked to provide the Trust with written consent to retain their data which will be securely held as evidence of compliance. We will also stay up to date with guidance and practice of GDPR and will seek additional input from the Information Commissioners Office should any uncertainties arise. We will review data protection and what data is held and who has access to it on a regular basis.

The Trust have contracted for services from the following 3rd party data processors:

The Trust has scrutinised their Terms and Conditions and judge that they are GDPR compliant. In fact in the first two services no stakeholder data is provided. The Bulk Email service simply receives a list of email addresses.

Stakeholders can request access to the data we hold on them by contacting the Trust Secretary and we will normally deal with a request within 14 days. A record will be kept of the date of the request and the date of the response.

Where a data breach has occurred action will be taken to minimise the harm. We will seek to rectify the cause of the breach as soon as possible. We will contact the Information Commissioners Office within 72 hours of the breach being reported. We will contact the relevant members to inform them of the data breach and actions taken to resolve it.

If a stakeholder contacts us feeling that there has been a breach, he/she will be asked to produce an email or a letter detailing their concern. We then will investigate the breach. The Member will also be informed that he/she can report their concerns to the Information Commissioners Office. Breach matters will be subject to a full investigation, records will be kept and all those involved notified of the outcome.

Policy review date: 03/20

City of Winchester Trust Council
June 2018