Data Policy

Data Protection Policy

1. Introduction

Scottish Women's Institutes needs to collect and use certain types of information about the Individuals or Service Users who come into contact with the Scottish Women's Institutes in order to carry on our work. This personal data must be collected and dealt with appropriately whether is collected on paper, stored in a computer database, or recorded on other material and there are safeguards to ensure this under the General Data Protection Regulation (GDPR).

2. Data Controller / Privacy Officer

The Scottish Women's Institutes is the Data Controller in relation to its members under the GDPR, which means that it determines what purposes personal data held, will be used for. It is also responsible for notifying the Information Commissioners Office (ICO) of the personal data it holds or is likely to hold, and the general purposes that this personal data will be used for.  Raymond Pratt is the Privacy Officer  Contact e-mail gensec@theswi.org.uk Tel 0131 2251724].

3. Disclosure

The Scottish Women's Institutes will not share personal data with other agencies/ individuals unless the member has freely given specific, informed and unambiguous consent.

The Individual/Service User will be made aware of how and with whom their information will be shared.  
Scottish Women's Institutes regards the lawful and correct treatment of personal data as very important to successful working, and to maintaining the confidence of those with whom we deal.  

Scottish Women's Institutes intends to ensure that personal data is treated lawfully and correctly.

To this end, the Scottish Women's Institutes will adhere to the Principles of Data Protection, as detailed in the GDPR.  The SWI will ensure compliance with the GDPR and any other data protection legislation as and when it comes into effect. Specifically, the Principles require that personal data:

1.  Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met,
2. Shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes,
3. Shall be adequate, relevant and not excessive in relation to those purpose(s) 
4. Shall be accurate and, where necessary, kept up to date,
5. Shall not be kept for longer than is necessary
6. Shall be processed in accordance with the rights of data subjects under the Act,
7. Shall be kept secure by the Data Processor who takes appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal data,

The Scottish Women's Institutes will, through appropriate management and strict application of criteria and controls demonstrate compliance with the data protection principles showing accountability:

• Observe fully conditions regarding the fair collection and use of information
• Meet its legal obligations to specify the purposes for which information is used
• Collect and process appropriate information, and only to the extent that it is needed to fulfill its operational needs or to comply with any legal requirements
• Ensure the quality of information used
• Ensure that the rights of people about whom information is held, can be fully exercised under the Act. These include: 
  • The right to be informed that processing is being undertaken,
  • The right of access to one’s personal data
  • The right to prevent processing in certain circumstances and
  • The right to correct, rectify, block or erase information which is regarded as wrong information)
• Take appropriate technical and organisational security measures to safeguard personal data
• Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information
• Set out clear procedures for responding to requests for information

4. Data Collection

Specific, informed and unambiguous  consent is when

• An Individual Member clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data
• And then gives their consent by a clear affirmative action.

The Scottish Women's Institutes will ensure that personal data is collected within the boundaries defined in this policy. This applies to personal data that is collected in person, or by completing a form.

When collecting personal data, the Scottish Women's Institutes will ensure that the Individual Member:

1. Clearly understands why the information is needed
2. Understands what it will be used for and what the consequences are should the Individual Member decide not to give consent to processin
3. As far as reasonably possible, grants clear affirmative consent, either written or verbal for data to be processed
4. Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress
5. Has received sufficient information on why their data is needed and how it will be used

5. Data Storage

Information and records relating to service users will be stored securely and will only be accessible to authorised staff and volunteers.

Information will be stored for only as long as it is needed or required statute and will be disposed of appropriately.

It is the Scottish Women's Institutes responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organisation, which has been passed on/sold to a third party.

6. Data Subject Rights

Data subjects have the following rights regarding data processing, and the data that is recorded about them:

• To make subject access requests regarding the nature of information held and to whom it has been disclosed.
• To prevent processing likely to cause damage or distress.
• To prevent processing for purposes of direct marketing.
• To be informed about the mechanics of automated decision-taking process that will significantly affect them.
• To not have significant decisions that will affect them taken solely by automated process.
• To sue for compensation if they suffer damage by any contravention of the GDPR.
• To take action to rectify, block, erased, including the right to be forgotten, or destroy inaccurate data.
• To request the ICO to assess whether any provision of the GDPR has been contravened.
• To have personal data provided to them in a structured, commonly used and machine-readable format, and the right to have that data transmitted to another controller.
•  To object to any automated profiling that is occurring without consent.

The Scottish Women's Institutes ensures that data subjects may exercise these rights:

• Data subjects may make data access;
• Data subjects have the right to complain to the Scottish Women's Institutes relating to the processing of their personal data, the handling of a request from a data subject and appeals from a data subject on how complaints have been handled in line with the Complaints Procedure.

The Scottish Women's Institutes will also take reasonable steps ensure that personal data is kept up to date by asking data subjects whether there have been any changes.

In addition, the Scottish Women's Institutes will ensure that:

• It will have a  Privacy Officer with specific responsibility for ensuring compliance with data protection requirements.
• Everyone processing personal data understands that they are contractually responsible for following good data protection practice
• Everyone processing personal data is appropriately trained to do so
•  Everyone processing personal data is appropriately supervised
• Anybody wanting to make enquiries about handling personal data knows what to do
• It deals promptly and courteously with any enquiries about handling personal data
• It describes clearly how it handles personal data
• It will regularly review and audit the ways it hold, manage and use personal data
• It regularly assesses and evaluates its methods and performance in relation to handling personal data
• All staff are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them

This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the GDPR.

In case of any queries or questions in relation to this policy please contact the Scottish Women's Institutes General Secretary.



Position: General Secretary/Privacy Officer
Date: 24th May 2018
Review Date: As legislation changes