Privacy Policy
Privacy Policy
Policy Statement

This policy applies to anyone working with personal data that is controlled or processed by or on behalf of CCG including and not limited to employees and members. Personal information means any data or information, in paper or digital format, relating to a living individual.
 
CCG is required to process relevant personal data regarding members of staff and data received from our clients and suppliers. This policy sets out our commitment to protecting personal data and how we will ensure that staff understand how to handle data they have access to a part of their work and how we implement that commitment with regards to the collection and use of personal data.
 
Commitments

We are committed to:
  • meeting our legal obligations as laid down by the Data Protection Act 1998, and the General Data Protection Regulations;
  • ensuring that data is collected and used fairly and lawfully;
  • processing personal data only in order to meet our operational needs or fulfil legal requirements;
  • taking steps to ensure that personal data is up to date and accurate;
  • establishing appropriate retention periods for personal data;
  • ensuring that data subjects' rights can be appropriately exercised;
  • providing adequate security measures to protect personal data;
  • ensuring that a nominated officer (the Director) is responsible for data protection compliance and provides a point of contact for all data protection issues;
  • ensuring that all staff are made aware of good practice in data protection;
  • providing adequate training for all staff responsible for personal data;
  • ensuring that everyone handling personal data knows where to find further guidance;
  • ensuring that queries about data protection, internal and external to the organisation, is dealt with effectively and promptly;
  • regularly reviewing data protection procedures and guidelines within the organisation.
Data Protection Principals

CCG will comply with the Data Protection Act (DPA)and General Data Protection (GDPR) principles and ensure that personal data is:
  1. Processed fairly and lawfully and in a transparent manner;
  2. Obtained for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes;
  3. Adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed;
  4. Accurate and, where necessary, kept up to date;
  5. Processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
  6. Processed in accordance with the rights of data subjects under the Data Protection Act 1998;
  7. Not transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data, and that
  8. Appropriate technical and organisational measures shall be taken against unauthorised and unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
General Requirements

Under the DPA and GDPR:
  • Personal data will only be accessed by those who need to for work purposes;
  • Personal data will not be divulged or discussed except when performing normal work duties;
  • Personal data will be kept safe and secure at all times, including at the office, public areas, home or in transit;
  • Personal data will be regularly reviewed and updated;
  • Queries about data protection, internal and external to CCG will be dealt with effectively and promptly.
Information Sharing

Personal data may need to be shared with other organisations in order to deliver services or perform our duties e.g. HMRC, payroll agency. This can only be done where we have permission or there is a legal obligation for us to share. We do not sell, trade or rent any data that we receive from our employees, clients or suppliers. Data Sharing Agreements will be completed when and if there is a need to set up ‘on-going’ or ‘routine' information-sharing arrangements with third parties.

Privacy Impact Assessments (PIAS)

PIAS will be completed in situations to help identify and minimise risks to individuals. These will be completed in the following situations that involve personal data:
  • At the beginning of a new project or when implementing a new system
  • Before entering a data-sharing agreement
  • When major changes are introduced into a system or process
Complaints

Anyone who feels that CCG has broken the law in any way, can complain. Examples of this are when information has not been obtained fairly, it has not been handled securely or upon request for a copy of their information if they are not happy with CCG's response. Individuals who consider that data is inaccurate or out of date may also request, in writing, that the information be corrected or erased. They will receive a written response indicating whether or not CCG agrees and if so, the action to be taken. Individuals can also ask CCG to stop handling their personal information if they think this will cause them harm or distress.

Training

Data Protection training is important so that all staff understand their responsibilities. All employees must complete the mandatory training.

Policy Review

The Director has direct responsibility for coordinating the maintenance and review of this policy annually. Reviews will take into account changes in legislation, best practice, lessons learnt and in consultation with relevant IT service providers.

​Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct and may even lead to criminal prosecution. 

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
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