Data Protection Policy
The Giving Back Fund’s Data protection policy describes how personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.
Why this policy exists
This data protection policy ensures The Giving Back Fund:
· Complies with data protection law and follow good practice
· Protects the rights of staff, customers and partners
· Is open about how it stores and processes individuals’ data
Protects itself from the risks of a data breach
Data protection law
As a non-profit organization, we must look to and comply with both federal and state laws and regulations.
These laws and regulations apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The following are the individual federal statutes that apply to The Giving Back Fund and of which we adhere to:
1. Gramm-Leach-Bliley Act
2. Children’s Online Privacy Protection Act
People, risks and responsibilities
Policy scope
This policy applies to:
· The head office of The Giving Back Fund
· All branches of The Giving Back Fund
· All staff and volunteers of The Giving Back Fund
All contractors and other people working on behalf of The Giving Back Fund
It applies to all data that the company holds relating to identifiable individuals. This can include:
· Names of individuals
· Postal addresses
· Email addresses
· Telephone numbers
…plus any other information relating to individuals
Data protection risks
This policy helps to protect The Giving Back Fund from some very real data security risks, including:
· Breaches of confidentiality. For instance, information being given out inappropriately.
· Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Responsibilities
Everyone who works for or with The Giving Back Fund has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
However, these people have key areas of responsibility:
The board of directors is ultimately responsible for ensuring that The Giving Back Fund meets its legal obligations.
The President, Marc Pollick, is responsible for:
o Keeping the board updated about data protection responsibilities, risks and issues.
o Reviewing all data protection procedures and related policies, in line with an agreed schedule.
o Arranging data protection training and advice for the people covered by this policy.
o Handling data protection questions from staff and anyone else covered by this policy.
o Dealing with requests from individuals to see the data The Giving Back Fund holds about them (also called ‘subject access requests’).
Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
The IT department is responsible for:
o Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
o Performing regular checks and scans to ensure security hardware and software is functioning properly.
Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
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 managers.
The Giving Back Fund 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 guidelines below.
In particular, strong passwords must be used and they should never be shared.
Personal data should not be disclosed to unauthorized people, either 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 disposed of.
Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
Data storage
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.
When data is stored on paper, it should be kept 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, like on a 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 CD or DVD), 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 services.
Servers containing personal data should be stored in a secure location, away from general office space.
Data should be backed up frequently. Those backups should be tested regularly, in line with the company’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.
Data use
Personal data is of no value to The Giving Back Fund unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk 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 email, as this form of communication is not secure.
Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorized external contacts.
Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
Data Accuracy
The law requires The Giving Back Fund 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 The Giving Back Fund should put into ensuring its accuracy.
It is the responsibility of all employees who work with 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.
The Giving Back Fund will make it easy for data subjects to update the information The Giving Back Fund holds about them. For instance, via the company website.
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 database.
It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
Subject access requests
All individuals who are the subject of personal data held by The Giving Back Fund are entitled to:
Ask what information the company holds about them and why.
Ask how to gain access to it.
Be informed how to keep it up to date.
Be informed how the company is meeting its data protection obligations.
Providing information
The Giving Back Fund aims to ensure that individuals are aware that their data is being processed, and that they understand:
How the data is being used
How to exercise their rights
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.