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Stand Together Network

GDPR Policy

General Data Protection Regulations (GDPR) Policy Introduction

This Policy sets out the obligations of Stand Together Network 

,(“the Company”) regarding data protection and the rights of customers and business contacts (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”). The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. 

This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company. 

The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals. 

The Data Protection Principles

This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be: 

  • Processed lawfully, fairly, and in a transparent manner in relation to the data subject. 
  • 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. 
  • Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed. 
  • Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay. 
  • Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is 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 GDPR in order to safeguard the rights and freedoms of the data subject. 
  • 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. 

The Rights of Data Subjects

  • The GDPR sets out the following rights applicable to data subjects 
  • The right to be informed’ 
  • The right of access, 
  • The right to rectification, 
  • The right to erasure (also known as the ‘right to be forgotten’), 
  • The right to restrict processing, 
  • The right to data portability, 
  • The right to object; and 
  • Rights with respect to automated decision-making and profiling. 

Lawful, Fair, and Transparent Data Processing

The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies: 

  • The data subject has given consent to the processing of their personal data for one or more specific purposes; 
  • The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them; 
  • The processing is necessary for compliance with a legal obligation to which the data controller is subject; 
  • The processing is necessary to protect the vital interests of the data subject or of another natural person; 
  • The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or 
  • The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. 
  • If the personal data in question is “special category data” (also known as “sensitive personal data”) (for example, data concerning the data subject’s health), at least one of the following conditions must be met: 
  • The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so); 
  • The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent; 
  • The processing relates to personal data which is clearly made public by the data subject; 
  • The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity; 

Specified, Explicit, and Legitimate Purposes

The Company collects and processes the personal data set out in this Policy. 

This includes: 

  • Personal data collected directly from data subjects OR 
  • Personal data obtained from third parties. 
  • The Company only collects, processes, and holds personal data for the specific purposes set out in this Policy (or for other purposes expressly permitted by the GDPR). 
  • Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data. 

Adequate, Relevant, and Limited Data Processing

The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed). 

Accuracy of Data and Keeping Data Up-to-Date

  • The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject. 
  • The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate. 

Data Retention

  • The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed. 
  • When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay. 
  • For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy. 

Secure Processing

The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided later in this Policy. 

Accountability and Record-Keeping

The Company’s Data Protection Officer is Sue Halawa 

E-Mail: info@thelearningacademy.org.uk 

Tel: 02088870155 

The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the GDPR and other applicable data protection legislation. 

  • The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information: 
  • The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors; 
  • The purposes for which the Company collects, holds, and processes personal data; 
  • Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates; 
  • Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards; 
  • Details of how long personal data will be retained by the Company; and 
  • Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data. 

Data Protection Impact Assessments

  • The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data. 
  • Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following: 
  1. The type(s) of personal data that will be collected, held, and processed; 
  2. The purpose(s) for which personal data is to be used; 
  3. The Company’s objectives; 
  4. How personal data is to be used; 
  5. The parties (internal and/or external) who are to be consulted; 
  6. The necessity and proportionality of the data processing with respect to the