Information assurance and data protection: appropriate policy document

Data protection principles

Article 5 of the UK General Data Protection Regulation outlines the six data protection principles (detailed below) which must be adhered to when processing personal data.

Article

5(1)(a) – Lawfulness, fairness and transparency

Processed lawfully, fairly and in a transparent manner in relation to individuals.

Approach

We will:

• ensure that personal data is only processed where a lawful basis applies
• process personal data fairly, and inform data subjects about the purposes of any processing
• ensure that data subjects receive full privacy information via a privacy notice, which will include the period for which personal data will be retained

Article

5(1)(b) – Purpose limitation

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.

Approach

We will:

• collect personal data for specified, explicit and legitimate purposes and inform data subjects what those purposes are via a privacy notice
• not use personal data for purposes that are incompatible with the purposes for which it was collected. If we do use data for a new purpose which is compatible, we will inform the data subject first

Article

5(1)(c) – data minimisation

Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Approach

We will:

• only collect the minimum personal data that we need for the purpose for which is it collected. We will make sure that the data we collect is accurate and relevant

Article

5(1)(d) – accuracy

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.

Approach

We will:

• ensure that personal data is accurate, and kept up to date where necessary. We will take particular care to do this where our use of the personal data has a significant impact on individuals

Article

5(1)(e) – storage limitation

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 implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals.

Approach

We will:

• only keep personal data in an identifiable form as long as is necessary for the purposes for which it is collected, where we have a legal obligation to do so, or for archiving, scientific or historical research, or statistical purposes. WW Once we no longer need personal data it will be deleted, put beyond use or anonymized

Article

5(1)(f) – integrity and confidentiality (security)

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.

Approach

We will:

• ensure that there are appropriate organisational and technical measures in place to protect personal data

Article

5(2) – accountability

The controller shall be responsible for, and be able to demonstrate, compliance with the principles.

Approach

We will: 

• keep records of all personal data processing activities and provide these to the Information Commissioner on request
• undertake a data protection impact assessment for all projects that involve personal data or privacy, with particular attention to high-risk processing activities
• consult the Information Commissioner when preparing proposals for legislation which relates to processing of personal data

To meet the overarching requirement of accountability we maintain adequate records of our data processing activities and keep evidence of how we comply with the data protection principles.