Data Protection Policy

Scope of the policy

This policy applies to the work of Kibworth & District U3A (hereafter ‘K&D U3A’). The policy sets out the requirements that K&D U3A has to gather personal information for membership purposes. The policy details how personal information will be gathered, stored and managed in line with data protection principles and the General Data Protection Regulation. The policy is reviewed on an ongoing basis by K&D U3A committee members to ensure that we remain compliant. This policy should be read in tandem with K&D U3A’s Privacy Policy.

 Why this policy exists

This data protection policy ensures that K&D U3A:

·       Complies with data protection law and follows good practice.

·       Protects the rights of members.

·       Is open about how it stores and processes members’ data.

·       Protects itself from the risks of a data breach.

 General guidelines for committee members and group leaders

·       The only people able to access data covered by this policy should be those who need to communicate with or provide a service to the K&D U3A members.

·       K&D U3A will provide induction training to committee members and group leaders to help them understand their responsibilities when handling data.

·       Committee Members and group leaders should keep all data secure, by taking sensible precautions and following the guidelines below.

·       Strong passwords must be used and they should never be shared.

·       Data should not be shared outside of K&D U3A unless with prior consent and/or for specific and agreed reasons. An example would include Gift Aid information provided to HMRC.

·       Member information should be refreshed periodically to ensure accuracy via the membership renewal process or when policy is changed.

·       Additional support will be sought from the Third Age Trust where uncertainties or incidents regarding data protection arise.


Data protection principles

The General Data Protection Regulation identifies key data protection principles:

 Principle 1 - Personal data shall be processed lawfully, fairly and in a transparent manner.

 Principle 2 - Personal data can only be 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.

 Principle 3 - The collection of personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

 Principle 4 – Personal data held should be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate are erased or rectified without delay.

 Principle 5 – Personal data must kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for the 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 GDPR in order to safeguard the rights and freedoms of individuals.

 Principle 6 - Personal data must be 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.


Lawful, fair and transparent data processing

K&D U3A requests personal information from potential members and members for membership applications and for sending communications about their involvement with K&D U3A. The forms used to request personal information will contain a privacy statement informing potential members and members as to why the information is being requested and what the information will be used for. The lawful basis for obtaining member information is due to the contractual relationship that the U3A has with individual members. In addition members will be asked to provide consent for specific processing purposes. U3A members will be informed as to who they need to contact should they wish for their data not to be used for specific purposes for which they have provided consent. Where these requests are received they will be acted upon promptly and the member will be informed as to when the action has been taken.


Processed for Specified, Explicit and Legitimate Purposes

Members will be informed as to how their information will be used and the Committee of K&D U3A will seek to ensure that member information is not used inappropriately. Appropriate use of information provided by members will include:

·       Communicating with members about K&D U3A’s events and activities

·       Group leaders communicating with their group members about specific group activities.

·       Sending members information about Third Age Trust events and activities.

·       Communicating with members about their membership and/or renewal of their membership.

·       Communicating with members about specific issues that may have arisen during the course of their membership.


K&D U3A will ensure that group leaders are made aware of what would be considered appropriate and inappropriate communication. Inappropriate communication would include sending U3A members marketing and/or promotional materials from external service providers.


K&D U3A will ensure that members' information is managed in such a way as to not infringe an individual members rights which include:

·       The right to be informed.

·       The right of access.

·       The right to rectification.

·       The right to erasure.

·       The right to restrict processing.

·       The right to data portability.

·       The right to object.


Adequate, Relevant and Limited Data Processing

Members of K&D U3A will only be asked to provide information that is relevant for membership purposes. This will include:

·       Name.

·       Postal address.

·       Email address.

·       Telephone number.


Members are invited to notify us of any physical or mental condition which may impact on their safe participation in K&D U3A. A confidential record of such data may be retained to help us ensure their safety.


Where K&D U3A organises a trip or activity that requires next of kin information to be provided, a legitimate interest assessment will have been completed in order to request this information. Members will be made aware that the assessment has been completed.



From time to time photographs may be taken of Group activities. Photographs are classified as personal data and members are fully entitled to request exclusion from all photographs without justification. Those responsible for taking such photographs should make members aware that pictures are being taken and the purpose of so doing. Members should alert the photographer of any desire to be excluded.

Should a member wish at any time to remove their consent and to have their photograph removed then they should contact the Newsletter Editor to advise that they no longer wish their photograph to be displayed.


Accuracy of Data and Keeping Data up to Date

K&D U3A has a responsibility to ensure members' information is kept up to date. Members will be informed to let the Membership Secretary know if any of their personal information changes. In addition, on an annual basis the membership renewal process will provide an opportunity for members to inform K&D U3A as to any changes in their personal information.


Accountability and Governance

The U3A Committee are responsible for ensuring that the U3A remains compliant with data protection requirements and can evidence that it has. Where consent is required for specific purposes then evidence of this consent (either electronic or paper) will be obtained and retained securely. The U3A Committee will ensure that new members joining the Committee receive an induction into the requirements of GDPR and the implications for their role. K&D U3A will also ensure that group leaders are made aware of their responsibilities in relation to the data they hold and process. Committee Members shall also stay up to date with guidance and practice within the U3A movement and shall seek additional input from the Third Age Trust National Office should any uncertainties arise. The Committee will review data protection and who has access to information on a regular basis as well as reviewing what data is held. When Committee Members and Group Conveners relinquish their roles, they will be asked to either pass on data to those who need it and/or delete data.


Secure Processing

K&D U3A committee members have a responsibility to ensure that data is both securely held and processed. This will include:

·       Committee members using strong passwords.

·       Committee members not sharing passwords.

·       Restricting access of sharing member information to those on the Committee who need to communicate with members on a regular basis.

·       Using password protection on laptops and PCs that contain or access personal information.

·       Using password protection or secure cloud systems when sharing data between committee members and/or group leaders.


Information Access Request

U3A members are entitled to request access to their information that is held by K&D U3A. The request needs to be received in the form of a written request to the Membership Secretary of K&D U3A. On receipt of the request, the request will be formally acknowledged and dealt with expediently (the legislation requires that information should generally be provided within one month) unless there are exceptional circumstances as to why the request cannot be granted. K&D U3A will provide a written response detailing all information held on the member. A record shall be kept of the date of the request and the date of the response.


Data Breach Notification

Were a data breach to occur, action shall be taken to minimise the harm. This will include ensuring all K&D U3A committee members are aware that a breach had taken place and how the breach occurred. The committee shall then seek to rectify the cause of the breach as soon as possible to prevent any further breaches. The Chair of K&D U3A shall contact National Office within 24 hours of the breach occurring to notify of the breach. A discussion would take place between the Chair and National Office as to the seriousness of the breach, action to be taken and, where necessary, the Information Commissioner's Office would be notified. The committee shall also contact the relevant U3A members to inform them of the data breach and actions taken to resolve the breach.

 Where a U3A feels that there has been a breach by K&D U3A, a committee member will ask the member to provide an outline of their concerns. If the initial contact is by telephone, the committee member will ask K&D U3A member to follow this up with an email or a letter detailing their concern. The alleged breach will then be investigated by members of the committee who are not in any way implicated in the breach. Where the committee needs support or if the breach is serious they should notify National Office. The member should also be informed that they can report their concerns to National Office if they don't feel satisfied with the response from K&D U3A. Breach matters will be subject to a full investigation, records will be kept and all those involved notified of the outcome.


This policy was adopted on: 10th September 2019


Policy review date: September 2020