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Data protection and privacy policy

June 2018

INTRODUCTION
This policy is designed to explain to people, in plain English, what personal data is collected by TNRA, what it is used for, how it is kept and for how long, and a person’s rights over the use of their personal data.

1. RESPONSIBILITY OF TNRA COMMITTEE
The Committee of the Trinity Newington Residents’ Association (TNRA) acknowledges their overall responsibility for ensuring that:
a) Personal information relating to any person is collected, held and processed in accordance with the requirements of current data protection legislation (as at May 2018, the European General Data Protection Regulation).
b) All committee members involved with the collection, processing and disclosure of personal data are aware of their duties and responsibilities.
c) A Data Protection Controller (DPC) is appointed (from May 2018, this is the TNRA chair, Edward Heckels).
d) All communications from TNRA shall include a statement of a person’s right to opt out of receiving such communications.
e) This policy is reviewed from time to time to ensure that it continues to conform with current legislation and TNRA’s current activities.

2. FROM WHOM DO WE COLLECT DATA?
TNRA may collect and use information about a variety of people, such as:
a) our current and past members;
b) other local residents and “TNRA friends”;
c) other contacts in the local community;
d) officers, employees and contractors of Trinity House or their managing agents;
e) contacts at Southwark Council, local authorities and other Government bodies.

3. WHAT DATA DO WE COLLECT?
a) TNRA may collect and record a person’s name, address, e-mail address and telephone number.
b) TNRA records money paid by a person as an annual subscription to TNRA.
c) TNRA does not collect any person’s bank, credit card or debit card details.
d) TNRA may collect images of people attending our events (see section 8 below).

4. WHY DO WE COLLECT DATA?
TNRA collects and retains data in order to:
a) maintain membership records and collect annual subscriptions;
b) encourage lapsed members to re-join TNRA and new residents to join TNRA;
c) provide members with updates on news in Trinity Village and the surrounding area;
d) provide tenants with support in their discussions with Trinity House, their contractors and the managing agents of properties in Trinity Village;
e) provide residents with support in discussions with Southwark Council, other local authorities and other Government bodies; and
f) assist with organising and publicising our events, including selling tickets, where appropriate.

5. HOW DO WE COLLECT DATA?
a) From TNRA members. TNRA asks people applying to join TNRA to give their name, address and e-mail address. Provision of these is taken as permission for TNRA to use them for the purposes listed in section 4.
b) From other local residents and “TNRA friends”. TNRA keeps a list of names and e-mail addresses of people who have asked to be informed about TNRA events.
c) Telephone numbers. In some of the circumstances listed in section 4, a person may provide a telephone number for ease of communication.
d) Public bodies, their representatives and employees. Details are publicly available.
e) Other bodies. Details may be obtained or given to TNRA for specific projects.

6. HOW DO WE KEEP DATA SAFE?
a) Personal data collected by TNRA is kept in a database on a secure website hosted by a UK server. Access to the website is limited to persons authorised by the committee to process the data.
b) At any time, a person may ask the DPC for details of their personal data in TNRA’s records.
c) TNRA will not divulge any personal details held on our database without permission of the person concerned. Any request for personal details will be forwarded by the DPC to the person whose details are requested.

7. FOR HOW LONG DO WE KEEP DATA?
a) TNRA will remove a person’s personal data from our records immediately if the person requests this.
b) TNRA will maintain personal data for as long as necessary to achieve the purposes for which the data was collected. For example, we shall retain names and addresses of lapsed TNRA members in order to contact them to renew their subscriptions.
c) Completed subscription forms and printouts of the data used for recruitment, accounting or other purposes will be kept safely by persons authorised by the committee and destroyed when the purpose for which they were processed is over. For example, accounts records may be kept for six years.

8. USE OF PHOTOGRAPHS
From time to time, TNRA may wish to use photographs or images of members and residents for the following purposes:
a) Printed marketing materials and media, including (but not exclusive to):
- TNRA’s semi-annual printed newsletter; and
- any publication produced by Trinity House or their managing agents to which TNRA supplies text and images on request.
b) Online, including our own website.
c) Any social media in which TNRA chooses to participate (eg, Facebook) and any social media sites used by our wider community including, but not exclusive to, other local residents’ associations and other groups.

Where possible, TNRA will endeavour not to identify individuals in photographs. However, as this is not always possible and given that TNRA wants to celebrate its activities and achievements on behalf of the local community, in some instances individual names will be published (on and off line) alongside their photograph, subject to written consent having been sought.