C2 National Network of Connected Communities (C2NN) is committed to the protection of all personal and sensitive data for which it holds responsibility as the Data Controller and the handling of such data in line with GDPR data protection principles and the Data Protection Act (DPA).
Changes to data protection legislation shall be monitored and implemented in order to remain compliant with all requirements.
The trustee responsible for data protection is: Hazel Stuteley: Chair
C2NN is also committed to ensuring that trustees are aware of data protection policies, legal requirements and adequate training is provided to them.
The requirements of this policy are mandatory for all C2NN trustees and any third party contracted to provide services to C2NN.
Reported breaches of C2NN data shall be notified immediately to the individual(s) concerned by the C2NN Data Protection Officer.
Personal and Sensitive Data:
All data within C2NN’s control shall be identified as personal, sensitive or both to ensure that it is handled in compliance with legal requirements and access to it does not breach the rights of the individuals to whom it relates.
The principles of the Data Protection Act shall be applied to all C2NN data processed:
- Processed fairly and lawfully
- Obtained only for lawful purposes, and is not further used in any manner incompatible with those original purposes
- Accurate and, where necessary, kept up to date,
- Adequate, relevant and not excessive in relation to the purposes for which it is processed
- Not kept for longer than is necessary for those purposes
- Processed in accordance with the rights of data subjects under GDPR
- Protected by appropriate technical and organisational measures against unauthorised or unlawful processing and against accidental loss, destruction or damage
- Not transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection of the personal information
Fair Processing / Privacy Notice:
We shall be transparent about the intended processing of data and communicate these intentions via notification to individual or group.
Notifications shall be in accordance with GDPR guidance and, where relevant, be written in a form understandable to all who request access to C2NN data.
The intention to share data relating to individuals to an organisation outside of C2NN shall be clearly defined within notifications and details of the basis for sharing given. Data will be shared with external parties only in circumstances where it is a legal requirement to provide such information.
Any proposed change to the processing of individual’s data shall first be notified to them.
In order to assure the protection of all data being processed and inform decisions on processing activities, C2NN will undertake an assessment of the associated risks of proposed processing and equally the impact on an individual’s privacy in holding data related to them.
Risk and impact assessments shall be conducted in accordance with GDPR guidelines.
Security of data shall be achieved through the implementation of proportionate physical and technical measures. C2NN data protection officer shall be responsible for the effectiveness of the controls’
The security arrangements of any organisation with which C2NN data is shared shall also be considered and these organisations shall provide evidence of the competence in the security of shared data.
Data Access Requests (Subject Access Requests):
All individuals whose data is held by us, have a legal right to request access to such data or information about what is held. We shall respond to such requests within 40 days and they should be made in writing to: Hazel Stuteley, Churchfields, Mullion, Helston, Cornwall TR12 7HR
Photographs and Video:
Images & DVD footage of C2NN associates may be captured at appropriate times and as part of educational activities for use at C2NN Learning Programmes only. A bespoke consent form is attached as Appendix 1.
Unless prior consent has been given, C2NN shall not utilise such images for publication or communication to external sources.
C2NN recognises that the secure disposal of redundant data is an integral element to compliance with legal requirements and an area of increased risk.
All data held in any form of media (paper, tape, electronic) shall only be passed to a disposal partner with demonstrable competence in providing secure disposal services.
All data shall be destroyed or eradicated to agreed levels meeting recognised national standards, with confirmation at completion of the disposal process.
C2NN has identified a qualified source for disposal of IT assets and collections.
Stuteley Chair C2NN 12/4/18