Data Protection Policy

toogoodtowaste needs to gather information about individuals. These include staff, volunteers, placements, customers, suppliers, business contacts, and other people the organization has contact with or may have the need to contact. The Policy describes how this personal data is collected, handled, and stored to meet the data protection standards and comply with the law.

toogoodtowaste’s Data Protection Policy ensures:

• Compliance with data protection law and following good practice

• Protection of the rights of staff, volunteers, placements, customers, and partner organizations

• The organization is open about how it stores and processes individuals’ data

• It protects the organization from the risks of a data breach

The Data Protection Act 1998 describes how organizations, including toogoodtowaste must collect, handle, and store personal information. The rules apply regardless of whether data is stored electronically, on paper, or on other material.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

Underpinned by eight important principles, the Data Protection Act states that personal data must:

• Be processed fairly and lawfully

• Be obtained only for specific, lawful purposes

• Be adequate, relevant and not excessive

• Be accurate and kept up to date

• Not be held for longer than necessary

• Processed in accordance with the rights of data subjects

• Be protected in appropriate ways

• Not be transferred outside the European Economic Area (EEA) unless that country or territory ensures an adequate level of protection

This policy applies to:

• All premises of toogoodtowaste, including branches in Ynyshir, Aberaman, and Treorchy

• All Staff, Volunteers and Placements

• All contractors, suppliers and other people working on behalf of toogoodtowaste

It applies to all data that the organization holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

• Names of individuals

• Postal addresses

• E-mail addresses

• Telephone numbers

• …plus other information relating to individuals

This policy is in place to help protect toogoodtowaste from data security risks including:

• Breaches of confidentiality. For instance, information given out inappropriately

• Failing to offer choice. For instance, all individuals should be free to choose how the company uses the data relating to them

• Reputational damage. For instance, the company could suffer if a hacker successfully gained access to sensitive data

The purpose of this policy is to enable toogoodtowaste to:

• Comply with the law in respect of the data it holds about individuals

• Protect toogoodtowaste’s supporters, staff, and other individuals, and

• Protect the organization from the consequences of a breach of its responsibilities

toogoodtowaste will:

• Comply with both the law and good practice

• Respect individuals’ rights

• Be open and honest with individuals whose data is held, and

• Provide training and support for staff and volunteers who handle personal data, so that they can act confidently and consistently

Everyone who works for toogoodtowaste, whether paid or unpaid, has some responsibilities for ensuring data is collected, stored, and handled appropriately. Everyone who handles personal data must ensure that it is handled and processed in line with this policy and data protection principles; these individuals have key areas of responsibility:

This policy is not part of the contract of employment that employees are issued when they join toogoodtowaste, and toogoodtowaste may amend it at any time. However, it is a condition of employment that employees and others who obtain, handle, process, transport, and store personal data will adhere to the rules of the policy. Any breach of the policy will be taken seriously and may result in disciplinary action.

The Board of Directors (Trustees) has ultimate responsibility for ensuring that toogoodtowaste meets its legal obligations. The data protection officer (Chief Executive Officer) is responsible for:

• Keeping the Board updated about data protection responsibilities, risks, and issues

• Reviewing all data protection procedures and related policies, in line with an agreed schedule

• Arranging data protection training and advice for people covered by this policy

• Handling data protection questions from staff and anyone else covered by this policy

• Dealing with requests from individuals to see the data toogoodtowaste holds about them (called ‘subject access requests’)

• Checking or approving any contracts or agreements with third parties that may handle the company’s sensitive data

• Ensuring all systems and equipment used for storing data meet acceptable security standards

• Performing regular checks and scans to ensure security hardware and software are functioning properly

• Evaluating any third-party services the organization is considering using to store or process data, for instance, cloud computing services

The Marketing Coordinator is responsible for:

• Approving any data protection statements attached to communications such as e-mails and letters

• Addressing any data protection queries from journalists or media outlets like newspapers

• Working with other staff to ensure marketing initiatives abide by data protection principles

General Staff Guidelines

• The only people able to access data covered by this policy should be those who need it for their work

• Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers

• toogoodtowaste will provide training to all employees to help them understand their responsibilities when handling data

• Employees should keep all data secure, by taking sensible precautions and following the data storage guidelines below

• In particular, strong passwords must be used and never shared

• Personal data should not be disclosed to unauthorized people, within the company or externally

• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and safely disposed of

• Employees should request help from their line manager or the Chief Executive Officer if they are unsure about any aspect of data protection

Data Storage The rules below describe how and where data should be stored safely. Questions about storing data safely should be directed to the individual’s line Manager or the Chief Executive Officer.

When data is stored on paper, it should be stored in a secure place where unauthorized people cannot see it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

• When not required, the paper or files should be kept in a locked drawer or filing cabinet

• Employees should make sure paper and printouts are NOT left where unauthorized people could see them, for example, on the printer

• Data printouts should be shredded and disposed of securely when no longer required

When data is stored electronically, it must be protected from unauthorized access, accidental deletion, and malicious hacking attempts:

• Data should be protected by strong passwords that are changed regularly and never shared between employees

• If data is stored on removable media (like a data stick, CD, etc), these should be kept locked away securely when not being used

• Data should only be stored on designated drives and servers and should only be uploaded to an approved cloud computing service, for example, Evide Impact Tracker

• Servers containing personal data should be sited in a secure locked location away from general office space

• Data should be ‘backed up’ frequently. Those backups should be tested regularly, in line with toogoodtowaste’s standard backup procedures

• Data should never be saved directly to laptops or other mobile devices like tablets or smartphones

• All servers and computers containing data should be protected by approved security software and a firewall

Personal data is of no value to toogoodtowaste unless the organization can make use of it. However, it is when personal data is accessed and used that it can be at the greatest use of loss, corruption or theft:

• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended

• Personal data should not be shared informally. In particular, it should never be sent by e-mail as this form of communication is not secure

• Data must be encrypted before being transferred electronically

• Personal data should never be transferred outside of the European Economic Area

• Staff should not save copies of personal data to their computers. Always access and update the central copy of any data

The law requires toogoodtowaste to take reasonable steps to ensure data is kept accurate and up to date; the more important it is that the personal data is accurate, the greater the effort toogoodtowaste should put into ensuring its accuracy.

It is the responsibility of all employees who work with the data to take reasonable steps to ensure it is kept as accurate and up to date as possible:

• Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets

• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call

• Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the toogoodtowaste database

• toogoodtowaste will ensure that any and all marketing databases are checked against ‘industry suppression files’ every six months

All individuals who are the subject of personal data held by toogoodtowaste including the staff team’s employment records are entitled to:

• Ask what information the company holds on them and why

• Gain access to it

• Be informed on how to keep it up to date

• Be informed how toogoodtowaste is meeting its data protection obligations

If an individual contacts toogoodtowaste requesting this information, it is called a ‘subject access request’. Subject access requests from individuals should normally be made by e-mail to the data controller (Marketing & Communications Officer & Assistant to CEO) at KBlake@toogoodtowaste.co.uk Where a volunteer or placement makes this request, their direct Supervisor should support the request and write the e-mail if required.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

In certain circumstances, the Data Protection act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, toogoodtowaste will disclose the data requested. However, the data controller will ensure the request is legitimate, seeking assistance from the Board and from toogoodtowaste’s legal advisors where necessary.

toogoodtowaste will strive to ensure that individuals are aware that their data is being processed and that they understand:

• How the data is being used

• Why it is being kept

• How to access the information

• How to exercise their rights