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Ner Yisrael Community Data Protection Policy 

 
Definitions
 
Charity
means Ner Yisrael Educational Trust a registered charity
DPR
means the Data Protection Regulation
Responsible Person
means the Data Protection Officer
Register of Systems
means a register of all systems or contexts in which personal data is processed by the Charity
Member
means one who is a member or associate of the Ner Yisrael Synagogue
 
1. Data protection principles
The Charity controls and processes personal information about Members, employees and volunteers of the Charity under EU data protection legislation. The Charity is committed to processing data in accordance with its responsibilities under the DPR.
 
The DPR requires that personal data shall be:
1. processed lawfully, fairly and in a transparent manner in relation to individuals;
2. 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;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. 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;
5. 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 DPR in order to safeguard the rights and freedoms of individuals; and
6. 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
1. This policy applies to all personal data processed by the Charity.
2. The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy.
3. This policy shall be reviewed from time to time.
4. The Charity shall register with the Information Commissioner’s Office as an organisation that processes personal data.
 
3. Lawful, fair and transparent processing
1. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.
2. The Register of Systems shall be reviewed at least annually.
3. 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. At the discretion of the Responsible Person and where permitted by law, the Charity may charge for this service.
 
4. Lawful purposes
1. 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.
2. The Charity shall note the appropriate lawful basis in the Register of Systems.
3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
4. 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. Members may, on request, be given a list of names and addresses of Members for the purpose of sending invitations to Simchas (this list is known as the “Simcha List”). The list shall be used for this purpose only and not shared with any other party. This list should be deleted once the specified Simcha has passed.
6. The Ner Yisrael Gemach, registered charity no. 1184874, may, on request to the Charity, be provided with a list of names and email addresses of Members for the purpose of contacting them regarding supporting the charitable aims of the Ner Yisrael Gemach. This list shall be used for this purpose only and not shared with any other party.
 
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.
 
6. Accuracy
1. The Charity shall take reasonable steps to ensure personal data is accurate.
2. 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.
 
7. Archiving / removal
1. To ensure that personal data is kept for no longer than necessary or for a period of no longer than 10 years.
2. The archiving policy shall consider what data should/must be retained, for how long, and why.
 
8. Security
1. The Charity shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
2. 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.
3. When personal data is deleted this should be done safely such that the data is irrecoverable.
4. Appropriate back-up and disaster recovery solutions shall be in place.
5. Physical records of personal data shall be stored using appropriate security measures
 
9. Breach
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.
 
END OF POLICY
Mon, 9 December 2024 8 Kislev 5785