Charity means Behind Every Kick which is registered with the Charity Commission for England and Wales as a charitable incorporated organisation under registration number 1177250.
GDPR means the General Data Protection Regulations which came into effect on 25 May 2018.
Responsible Person means Debra Fox, Executive Director Behind Every Kick.
Register of Systems means a register of all systems or contexts in which personal data is processed by the Charity.
1. Data protection principles
The Charity is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. 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;
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;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;
d. 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;
e. 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; and
f. 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
a. This policy applies to all personal data processed by the Charity.
b. The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy.
c. This policy shall be reviewed at least annually.d. The Charity shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
a. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.
b. The Register of Systems shall be reviewed at least annually.
c. 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.
4. Lawful purposes
a. 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 (see ICO guidance for more information).
b. The Charity shall note the appropriate lawful basis in the Register of Systems.
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
d. 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. Examples of how we may use your data
- To inform you of dates and locations for Development Sessions, workshops and other events which we think may be relevant to you
- To contact you in response to a specific enquiry or request
- To be able to evaluate our services based on your feedback and to measure and monitor our impact based on how you respond to our questionnaires.
In line with data protection laws, you still have the right to opt out at any time.
6. Use of Photographs, Films and Video footage
From time to time we take photographs and/ video footage of Development Sessions, workshops and other events.
Wherever possible, we ensure that we have received consent on behalf of all participants by virtue of each sports club /school having agreed to photo and filming for authorized purposed via the Behind Every Kick application process. Wherever possible and in addition to the above, we also ask seek permission of participants who we may be photographing and /filming at the start of any session and /event.
We endeavor to keep these photographs and video footage digitally secure on password-protected phones, computers and hard drives, to safeguard them from misuse, loss, or unauthorized access. We cannot legislate for drives or files which may become corrupt over time.
From time to time, we use these photos, films and video footage on our website and social media to promote Behind Every Kick and demonstrate its impact.
7. 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.
a. The Charity shall take reasonable steps to ensure personal data is accurate.
b. 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.
9. Archiving / removal
a. To ensure that personal data is kept for no longer than necessary, the Charity shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
b. The archiving policy shall consider what data should/must be retained, for how long, and why.
a. The Charity shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
b. 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.
c. When personal data is deleted this should be done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.
a. 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 (more information on the ICO website).