This page comprises several sections relating to GDPR (General Data Protection Regulation) and is a statement made by Home-Start Barnet, Brent & Harrow (Home-Start Barnet) on 21st May 2018. Use the buttons below to navigate throughout the page to the sections listed below.
Home-Start Barnet, Brent & Harrow (Home-Start Barnet)
General Data Protection Regulations – Compliance Statement
Home-Start is one of the leading family support charities in the UK. Home-Start volunteers help families with young children deal with the challenges they face. We support parents as they learn to cope, improve their confidence and build better lives for their children.
Information Commissioners Office (ICO) Registration
Home-Start Barnet has registered with the Information Commissioners Office (ICO) under registration reference Z1933456
Home-Start Barnet are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We recognise our obligations in updating and expanding this program to meet the demands of the GDPR.
Home-Start Barnet are dedicated to safeguarding the personal information and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
How we are preparing for the GDPR
Home-Start Barnet already have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR by 25th May 2018. Our preparation includes: –
We will regularly carry out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed. Data Protection Impact Assessments (DPIA) have helped us develop stringent procedures and assessment templates for carrying out impact. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
Policies and procedures
We have revised our data protection policies and procedures to meet the requirements and standards of the GDPR including data protection, IT security, data retention and erasure, data breaches and third-party transfers and disclosures.
Home-Start Barnet have designated Raphael Harris, Trustee, as our Data Protection Officer and we have prompted awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.
Home-Start Barnet understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans, induction and annual training program. Staff will be given annual GDPR updates as a Quality Assurance requirement.
Subject Access Request (SAR)
We have introduced SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
We have revised our Privacy Statement(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
Data Transfer Statement
We have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. Home-Start Barnet will at times, on an anonymised basis, use personal information to demonstrate the impact of our services. Any case study information shared, will always be on an anonymised basis unless we have further explicit consent from individuals.
Home-Start Barnet may use data for specific purposes of statistical analysis and the promotion of our work nationally as well as any reporting requirements for funders who support the network on a national level.
Home-Start Barnet will share personal information with law enforcement or other authorities if required by applicable law (including, in line with our Safeguarding and Promoting the Welfare of Children/Safeguarding Adults at risks policies, where there are concerns about the safety or wellbeing of a child or adult at risk and it is considered necessary for their welfare and protection).
Home-Start Barnet will not share your personal information with any other third party without first obtaining your explicit consent.
We have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions. This includes a clear method for opting out and providing unsubscribe features on all subsequent marketing materials.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via our website, in the office, and during induction of an individual’s right to access any personal information that Home-Start Barnet processes about them and to request information about: –
- What personal data we hold about them
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from them, information about the source
- The right to have incomplete/inaccurate data corrected or completed and the process for requesting this
- The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
- The right to lodge a complaint or seek judicial remedy and who to contact in such instances
Right to be Forgotten/Subject Access Request
We have a right to erasure process. If you wish to be erased, please contact us via email@example.com or on 020 8371 0674 for our Subject Access Request information.
If you have any questions about our preparation for the GDPR, please contact our Data Protection Officer Raphael Harris. Tel: 020 8371 0674 Email: firstname.lastname@example.org or use our contact us page.
Information Security Measures (IT)
Home-Start Barnet takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including: –
Encryption & Data Access
Home-Start Barnet supports various encryption methods to protect the transition of data over both trusted and untrusted networks. Various technical security measures are also used including firewalls, VPNs, enterprise-grade antivirus, and auditable internet use. The organisation obtains destruction certificates when hard drives containing personal data are destroyed.
Home-Start Barnet tests, discover, investigate and fix vulnerabilities and perform regular vulnerability tests.
Access control (IT)
Employees are required to sign Confidentially Statements (HR contract) upon joining Home-Start Barnet and are required to undertake annual training. Access to data is highly restricted and is governed by access rights approved by managers.
External contractors for, e.g. our online server, cloud-based data storage or website management that may have access to the systems from time to time for the completion of maintenance, development and servicing tasks are under a strict non-disclosure agreement and need to know basis. Any information that they may have access to during their duties is closely managed by Home-Start Barnet. Information may not be used for any other purpose and is destroyed on completion of the task.
When a data storage device has reached the end of its useful life, Home-Start Barnet destroys data as part of a decommissioning process. All devices are destroyed in accordance with industry-standard practices.
Third-party certifications and audits are an important component of any mature security program.
A password policy requires staff to change passwords every 45 days. There are also rules about the complexity of passwords.
CharityLog Case Management (CLOG)
Home-Start Barnet use an internal data capture system to track outcomes based around the work they undertake with families they are supporting. With a limited amount of personal data included Home-Start Barnet take the following measures to ensure a high level of security within the system.
Access to data within CLOG is governed by access rights. Privileges can be configured and managed to define multi-level access rights.
Users are authenticated through username and password which is cross checked against an SQL (Structured Query Language) table within which the data is encrypted.
User are automatically logged out of CLOG after specific inactivity periods have lapsed.
CLOG has multi-level access procedures including a username and password protection process.
Failed authentication lock-outs are embedded. After 5 failed attempts users are locked out of CLOG for 10 minutes after which the system re-set is required by a system administrator.
Forgotten username or password
Home-Start Barnet has configurable built-in support to enable local administrators to enable and reset sub-user credentials and give limited access and exclusion to local staff and Trustees. Administrators can control number of users, but administrator rights are maintained and secured by Home-Start Barnet’s System administrator.
3rd Party Usage
All data collected by CLOG is consented to an anonymization process in order for 3rd party statistical analysis. 3rd parties are mandated to provide their own signed GDPR compliance statements and privacy policies.
New functionality is project planned by Dizion LTD who prioritise additions and changes to the system. Work is planned and authorised within agreed resources and timescales.
Fundraising & Website
Home-Start Barnet will share information with our payment services provider only to the extent necessary for the purposes of processing payments you make via our website, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
Disclosing personal information
Home-Start Barnet may disclose your personal information to any of our employees insofar as reasonably necessary to the extent that we are required to do so by law, in connection with any ongoing or prospective legal proceedings, in order to establish, exercise or defend our legal rights.
Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes to the extent that we are required to do so by law.
Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website. We use both session and persistent cookies on our website and Google Analytics to analyse the use of our website which generates statistical and other information about website use by means of cookies.
The ICO has issued an employment practices code which Home-Start Barnet follows for (1) Recruitment and Selection (2) Employment Records (3) Monitoring at Work and (4) Information about Workers’ Health. The retention checklist is divided into two parts (1) statutory & (2) non-statutory with recommended retention periods followed to CIPD industry standards.
The Home-Start Barnet office is secured by lock and key and the building is alarmed.
Key staff have keys to the office and other members of the team can request the office to be opened by Avenue House Estates staff using the master key. There is a designated open up and lock up procedure in our staff manual.
The offices are managed by Avenue House Estates and cannot access without permission.
Employee files and the data within are kept in lockable cabinets at the Home-Start Barnet offices at Stephens House, 17 East End Road, London N3 3QE. They can only be accessed by the authorisation of the CEO who holds the sole keys for the cabinet.
Right to be Forgotten/Subject Access Request
We have a right to erasure process. If you wish to be erased, or to withdraw processing consent, or delete/correct info then please contact please contact Home-Start Barnet via email@example.com or 020 8371 0674 for our Subject Access Request information.
We have a notification process in place for any breach. For further details on this, please contact Home-Start Barnet via firstname.lastname@example.org or 020 8371 0674 for our breach information and procedures.