The HVBA is bound to issue, update and abide by its own Data Protection Policy. This policy by law has to be updated annually. The policy (or the General Data Protection Regulation (GDPR) to give it it’s full title) is updated annually by the Management Committee. You can read the full policy below.

This policy should be read in conjunction with the website’s privacy policy.

Huddersfield Veterans Bowling Association Data Protection Policy

Last updated

12 March 2023

Definitions

HVBA  means Huddersfield Veterans Bowling Association

GDPR  means the General Data Protection Regulation.

Responsible Person  means the association General Secretary

Register of Systems  means a register of all systems or contexts in which personal data is processed by the HVBA

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​Data protection principles

The HVBA is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

1. processed lawfully, fairly and in a transparent manner in relation to individuals;
2. 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;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. 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;
5. 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; 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 the implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
6. 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.”

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General provisions

1. This policy applies to all personal data processed by the HVBA.
2. The Responsible Person shall take responsibility for the HVBA’s ongoing compliance with this policy.
3. This policy shall be reviewed at least annually.
4. The HVBA does not need to register with the Information Commissioner’s Office as an organisation that processes personal data.

Lawful, fair and transparent processing

1. To ensure its processing of data is lawful, fair and transparent, the HVBA shall maintain a Register of Systems.
2. The Register of Systems shall be reviewed at least annually.
3. Individuals have the right to access their personal data and any such requests made to the HVBA shall be dealt with in a timely manner.

Lawful purposes

1. All data processed by the HVBA must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
2. The HVBA notes the appropriate lawful basis in the Register of Systems.
3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in  consent shall be kept with the personal data.
4. 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 HVBA’s systems.

Data minimisation

1. The HVBA shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
2. The HVBA will retain data in paper and electronic form solely for the purpose of managing the objectives and business of the Association. When retained in electronic form it will wherever possible use MS Office applications.
3. Accuracy
4. The HVBA shall take reasonable steps to ensure personal data is accurate.
5. 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.
6. The HVBA will, wherever possible, use MS Office applications to retain personal data.

Archiving / removal

1. To ensure that personal data is kept for no longer than necessary, the HVBA shall delete all records when requested by the data subject.
2. The archiving policy states that no data will be archived and any data no longer required will be deleted from all our systems other than paper records.

Security

1. The HVBA shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
2. 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.
3. When personal data is deleted this should be done safely such that the data is irrecoverable.
4. Appropriate back-up and disaster recovery solutions shall be in place.

Breach

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 HVBA shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO.

END OF POLICY

APPENDIX 1

Huddersfield Veterans Bowling Association

Register of Systems

This represents the computer programmes used to process and store data about individuals and teams as well as the two websites that we use to store and share individual and team records.

Last updated 12 March 2023

1. MS Office Word
2. MS Office Excel
3. Adobe Acrobat
4. hvba.co.uk
5. bowlsnet.uk
6. Paper based records