This Policy applies to APWA UK including our website apwa.org.uk.
In this document ‘Organisation’ refers to APWA UK.
APWA UK is a charity organisation registered in England under the charity number: 1136005
The registered address is
1 Laurel Way,
London, E18 2UA
General Data Protection Regulation (GDPR) Definitions:
Processing identifies a wide range of activities that include obtaining, recording, holding and storing personal data and carrying out any operations on such data including analysis, segmentation, adaptation, alteration, use for reaching the individuals in question, disclosure, transfer, erasure and destruction.
Personal and special categories of personal data refer to any information relating to an identified (directly or indirectly) or identifiable natural person (‘data subject’). In particular, by reference to an identifier such as a name, identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Service users: refer to all private individuals who do business with [your organisation] or any of its subsidiaries including donors and supporters and community members. Services received include but are not limited to information requests, websites’ use, purchasing, making donations and or accessing goods and services.
This policy sets the Organisation’s obligations regarding the collection, processing, transfer, storage and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Organisation, its employees, agents, contractors or other parties working on behalf of the Organisation.
APWA UK is committed to the protection of the rights and freedoms of all individuals including staff, trustees, volunteers, service users and community members in accordance with the provisions of the General Data Protection Regulation (GDPR). As such APWA UK will comply fully with the requirements of the regulation by:
- Ensuring that all personal information is handled and dealt with in line with the regulation regardless of how it is collected, retained, or used and whether it is held electronically, on paper or other formats.
- Implementing procedures to ensure that all persons with access to personal data held by or on behalf of APWA UK are fully trained and aware of the relevant policies and procedures.
- Ensuring that all persons with such access to personal data will abide by their duties and responsibilities under the regulation in carrying out their APWA UK roles.
- Ensuring that accurate and proportionate records are kept to provide a good support framework for staff and volunteers, and to comply with employment, Charity and Company legal requirements.
- APWA UK will ensure that all persons on whom identification is held are notified and made aware of which data is held and how, why it is retained and for how long, and that they can request access to records held about them at any time.
- The Regulation relates to the processing of personal data and special categories of personal data (or sensitive data) which must be processed in accordance with the Regulation’s principles.
Principles of the GDPR
The Regulation stipulates that anyone processing personal data must comply with its principles which are legally binding. The principles require that personal data shall be:
- Processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’)
- Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
- 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 in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);
- 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 (‘integrity and confidentiality’).
- The controller (APWA UK) shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’).
- Consent to the processing must be given by a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of the data subject’s agreement to the processing of personal data relating to him or her, such as by a written statement, including by electronic means, or an oral statement.
- Processed in accordance to with Rights of the data subject.
The Rights of Data Subjects
The GDPR sets out the following rights applicable to data subjects:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure (also known as the ‘right to be forgotten’.)
- The right to restrict processing.
- The right to data portability.
- The right to object; and
- Rights with respect to automated decision-making and profiling.
Lawful, Fair, and Transparent Data Processing
The GDPR seeks to ensure that personal data is processed lawfully, fairly,
and transparently, without adversely affecting the rights of the data subject.
The GDPR states that processing of personal data shall be lawful if at least
one of the following applies:
1.The data subject has given consent to the processing of their personal
data for one or more specific purposes;
2.The processing is necessary for the performance of a contract to which
the data subject is a party, or in order to take steps at the request of
the data subject prior to entering into a contract with them;
3. The processing is necessary for compliance with a legal obligation to
which the data controller is subject;
4. The processing is necessary to protect the vital interests of the data
subject or of another natural person;
5. The processing is necessary for the performance of a task carried out
in the public interest or in the exercise of official authority vested in the
data controller; or
6. The processing is necessary for the purposes of the legitimate interests
pursued by the data controller or by a third party, except where such
interests are overridden by the fundamental rights and freedoms of the
data subject which require protection of personal data, in particular
where the data subject is a child.
If the personal data in question is “special category data” (also known as
“sensitive personal data”) (for example, data concerning the data subject’s
race, ethnicity, politics, religion, trade union membership, genetics, biometrics
(if used for ID purposes), health, sex life, or sexual orientation), at least one of
the following conditions must be met:
– The data subject has given their explicit consent to the processing of
such data for one or more specified purposes (unless EU or EU
Member State law prohibits them from doing so);
– The processing is necessary for the purpose of carrying out the
obligations and exercising specific rights of the data controller or of the
data subject in the field of employment, social security, and social
protection law (insofar as it is authorised by EU or EU Member State
law or a collective agreement pursuant to EU Member State law which
provides for appropriate safeguards for the fundamental rights and
interests of the data subject);
– The processing is necessary to protect the vital interests of the data
subject or of another natural person where the data subject is
physically or legally incapable of giving consent;
– The data controller is a foundation, association, or other non-profit
body with a political, philosophical, religious, or trade union aim, and
the processing is carried out in the course of its legitimate activities,
provided that the processing relates solely to the members or former
members of that body or to persons who have regular contact with it in
connection with its purposes and that the personal data is not
disclosed outside the body without the consent of the data subjects;
– The processing relates to personal data which is clearly made public by
the data subject;
-The processing is necessary for the conduct of legal claims or
whenever courts are acting in their judicial capacity;
-The processing is necessary for substantial public interest reasons, on
the basis of EU or EU Member State law which shall be proportionate
to the aim pursued, shall respect the essence of the right to data
protection, and shall provide for suitable and specific measures to
safeguard the fundamental rights and interests of the data subject;
– The processing is necessary for the purposes of preventative or
occupational medicine, for the assessment of the working capacity of
an employee, for medical diagnosis, for the provision of health or social
care or treatment, or the management of health or social care systems
or services on the basis of EU or EU Member State law or pursuant to
a contract with a health professional, subject to the conditions and
safeguards referred to in Article 9(3) of the GDPR;
-The processing is necessary for public interest reasons in the area of
public health, for example, protecting against serious cross-border
threats to health or ensuring high standards of quality and safety of
health care and of medicinal products or medical devices, on the basis
of EU or EU Member State law which provides for suitable and specific
measures to safeguard the rights and freedoms of the data subject (in
particular, professional secrecy); or
– The processing is necessary for archiving purposes in the public
interest, scientific or historical research purposes, or statistical
purposes in accordance with Article 89(1) of the GDPR based on EU or
EU Member State law which shall be proportionate to the aim pursued,
respect the essence of the right to data protection, and provide for
suitable and specific measures to safeguard the fundamental rights
and the interests of the data subject.
Specified, Explicit, and Legitimate Purposes
- apwa.org.uk collects and processes the personal data set out here:
-Name and title;
-Contact information such as email addresses, telephone numbers;
-Demographic information such as postcode, preferences and interests- a list of URL’s starting with a referring site, your activity on our site, and the site you exit to;
-Web browser type and version;
- This includes personal data collected directly from data subjects or from third parties.
- Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data.
Adequate, Relevant and Limited Data Processing
apwa.org.uk will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed as under section above, and as set out below.
Accuracy of Data and Keeping Data Up-to-Date
- apwa.org.uk shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out below.
- The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.
- apwa.org.uk shall not keep personal data for any longer than is necessary in light of the purpose(s) for which that personal data was originally collected, held and processed.
- When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.
apwa.org.uk shall ensure that all personal data collected, held and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage.
Accountability and Record-Keeping
APWA UK’s Data Champion (DC) is Susan Sinclair, email@example.com The DC has special responsibility for data protection to ensure data management is implemented in accordance to the regulation and ensure compliance at APWA UK. The DC will also be responsible for providing support and guidance to other members of staff and volunteers in the Company.
- The DC shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Organisation’s other data protection-related policies, and with the GDPR and other applicable data protection legislation.
- The DC shall manage the process in the event of a data breach.
- The DC will ensure that personal data is collected in a specific, explicit and unambiguous manner and for a legitimate stated purpose through adequate procedures on and off line; ensuring that we have a clear and unambiguous indication of the data subjects’ agreement for their data to be processed.
- The Data Champion will ensure that data subjects can exercise their full rights as stated in the Regulation. These include the right to be informed how their data will be used, the right to access one’s personal information, the right to rectify, erase, object and restrict processing in certain circumstances and their right to data portability.
- The DC will ensure that personal data is processed lawfully, fairly and in a transparent manner through appropriate management and systems.
- The DC will collect and process appropriate data only to the extent that it is needed to fulfil operational needs or to comply with legal requirements, that it is kept secure, it is accurate and held for no longer than is necessary.
Data Protection Impact Assessments
APWA UK shall carry out Data Protection Impact Assessments for any and
all new projects and/or new uses of personal data [which involve the use of
new technologies and the processing involved is likely to result in a high risk to
the rights and freedoms of data subjects under the GDPR].
Data Protection Impact Assessments shall be overseen by the Data Champion and shall address the following:
- The type(s) of personal data that will be collected, held, and
- The purpose(s) for which personal data is to be used;
- The Organisation’s objectives;
- How personal data is to be used;
- The parties (internal and/or external) who are to be consulted;
- The necessity and proportionality of the data processing with respect to
the purpose(s) for which it is being processed;
- Risks posed to data subjects;
- Risks posed both within and to the Organisation; and
- Proposed measures to minimise and handle identified risks.
Keeping Data Subjects Informed
The Organisation shall provide the information set out below to every data
- Where personal data is collected directly from data subjects, those
data subjects will be informed of its purpose at the time of collection;
- Where personal data is obtained from a third party, the relevant data
subjects will be informed of its purpose:
- a) if the personal data is used to communicate with the data subject,
when the first communication is made; or
- b) if the personal data is to be transferred to another party, before that
transfer is made; or
- c) as soon as reasonably possible and in any event not more than one
month after the personal data is obtained.
Data Subject Access
- Data subjects may make subject access requests (“SARs”) at any time to find
out more about the personal data which the Organisation holds about them, what
it is doing with that personal data, and why.
- Employees wishing to make a SAR should do using a Subject Access
Request Form, sending the form to the Company’s Data Champion (Susan Sinclair) at firstname.lastname@example.org
- Responses to SARs shall normally be made within one month of receipt,
however this may be extended by up to two months if the SAR is complex
and/or numerous requests are made. If such additional time is required, the
data subject shall be informed.
- All SAR’s received shall be handled by the Organisation’s Data Champion.
- The Organisation does not charge a fee for the handling of normal SARs. The
Organisation reserves the right to charge reasonable fees for additional copies of
information that has already been supplied to a data subject, and for requests
that are manifestly unfounded or excessive, particularly where such requests
Rectification of Personal Data
- Data subjects have the right to require the Organisation to rectify any of their
personal data that is inaccurate or incomplete.
- The Organisation shall rectify the personal data in question, and inform the data
subject of that rectification, within one month of the data subject informing the
Organisation of the issue. The period can be extended by up to two months in the
case of complex requests. If such additional time is required, the data subject
shall be informed.
- In the event that any affected personal data has been disclosed to third
parties, those parties shall be informed of any rectification that must be made
to that personal data.
Erasure of Personal Data
Data subjects have the right to request that the Organisation erases the personal
data it holds about them in the following circumstances:
- It is no longer necessary for the Organisation to hold that personal data
with respect to the purpose(s) for which it was originally collected or
- The data subject wishes to withdraw their consent to the Organisation
holding and processing their personal data;
- The data subject objects to the Organisation holding and processing their
personal data (and there is no overriding legitimate interest to allow the Organisation to continue doing so).
- The personal data has been processed unlawfully;
- The personal data needs to be erased in order for the Organisation to
comply with a particular legal obligation.
- Unless the Organisation has reasonable grounds to refuse to erase personal
data, all requests for erasure shall be complied with, and the data subject
informed of the erasure, within one month of receipt of the data subject’s
request. The period can be extended by up to two months in the case of
complex requests. If such additional time is required, the data subject shall be
- In the event that any personal data that is to be erased in response to a data
subject’s request has been disclosed to third parties, those parties shall be
informed of the erasure (unless it is impossible or would require
disproportionate effort to do so).
Restriction of Personal Data Processing
- Data subjects may request that the Organisation ceases processing the personal
data it holds about them. If a data subject makes such a request, the
Organisation shall retain only the amount of personal data concerning that data
subject (if any) that is necessary to ensure that the personal data in question
is not processed further.
- In the event that any affected personal data has been disclosed to third
parties, those parties shall be informed of the applicable restrictions on
processing it (unless it is impossible or would require disproportionate effort to
- The Organisation processes personal data using automated means.
- Where data subjects have given their consent to the Organisation to process their
personal data in such a manner, or the processing is otherwise required for
the performance of a contract between the Organisation and the data subject,
data subjects have the right, under the GDPR, to receive a copy of their
personal data and to use it for other purposes (namely transmitting it to other
- To facilitate the right of data portability, the Organisation shall make available all
applicable personal data to data subjects in the following format[s]:
- Where technically feasible, if requested by a data subject, personal data shall
be sent directly to the required data controller.
- All requests for copies of personal data shall be complied with within one
month of the data subject’s request. The period can be extended by up to two
months in the case of complex or numerous requests. If such additional time is
required, the data subject shall be informed.
Objections to Personal Data Processing
- Data subjects have the right to object to the Organisation processing their
personal data based on legitimate interests, direct marketing (including
profiling), [and processing for scientific and/or historical research and statistics
- Where a data subject objects to the Organisation processing their personal data
based on its legitimate interests, the Organisation shall cease such processing
immediately, unless it can be demonstrated that the Organisation’s legitimate
grounds for such processing override the data subject’s interests, rights, and
freedoms, or that the processing is necessary for the conduct of legal claims.
- Where a data subject objects to the Organisation processing their personal data
for direct marketing purposes, the Organisation shall cease such processing
- Where a data subject objects to the Organisation processing their personal data
for scientific and/or historical research and statistics purposes, the data
subject must, under the GDPR, “demonstrate grounds relating to his or her
particular situation”. The Organisation is not required to comply if the research is
necessary for the performance of a task carried out for reasons of public
Data Security – Transferring Personal Data and Communications
The Organisation shall ensure that the following measures are taken with respect to all
communications and other transfers involving personal data:
- All emails containing personal data must be marked “confidential”;
- Personal data contained in the body of an email, whether sent or received,
should be copied from the body of that email and stored securely. The email
itself should be deleted. All temporary files associated therewith should also
- Where personal data is to be sent by facsimile transmission the recipient
should be informed in advance of the transmission and should be waiting by
the fax machine to receive the data;
- Where personal data is to be transferred in hard copy form it should be passed
directly to the recipient using Royal Mail or a delivery service such as DHL/DPD. Or by hand directly to the recipient.
- All personal data to be transferred physically, whether in hard copy form or on
removable electronic media shall be transferred in a suitable container marked
Data Security – Disposal
When any personal data is to be erased or otherwise disposed of for any reason
(including where copies have been made and are no longer needed), it should be
securely deleted and disposed of.
Data Security – Use of Personal Data
The Organisation shall ensure that the following measures are taken with respect to the
use of personal data:
- No personal data may be shared informally and if an employee, agent, sub-
contractor, or other party working on behalf of the Organisation requires access
to any personal data that they do not already have access to, such access
should be formally requested from Susan Sinclair, email@example.com (Data Champion).
- No personal data may be transferred to any employees, agents, contractors,
or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of Susan Sinclair, firstname.lastname@example.org (Data Champion).
- Personal data must be handled with care at all times and should not be left
unattended or on view to unauthorised employees, agents, subcontractors, or
other parties at any time;
- If personal data is being viewed on a computer screen and the computer in
question is to be left unattended for any period of time, the user must lock the
computer and screen before leaving it; and
- Where personal data held by the Organisation is used for marketing purposes, it
shall be the responsibility of Susan Sinclair,( Data Champion) to ensure that the appropriate
consent is obtained and that no data subjects have opted out, whether directly
or via a third-party service such as the TPS.
Data Security – IT Security
The Organisation shall ensure that the following measures are taken with respect to IT
and information security:
- All passwords used to protect personal data should be changed regularly and
should not use words or phrases that can be easily guessed or otherwise
compromised. All passwords must contain a combination of uppercase and
lowercase letters, numbers, and symbols. [All software used by the Organisation
is designed to require such passwords.];
- All software (including, but not limited to, applications and operating systems)
shall be kept up-to- date. The Organisation’s IT staff/company shall be responsible for
installing any and all security-related updates to the website, after the updates are made available by the publisher or manufacturer.
The Organisation shall ensure that the following measures are taken with respect to the
collection, holding, and processing of personal data:
- All employees, agents, contractors, volunteers, Trustees or other parties working on behalf of the Organisation shall be made fully aware of both their individual responsibilities, the Organisation’s responsibilities under the GDPR , and under this Policy, and shall be provided with a copy of this Policy;
- Only employees, agents, subcontractors, or other parties working on behalf of
the Organisation that need access to, and use of, personal data in order to carry
out their assigned duties correctly shall have access to personal data held by
The Organisation ;
- All employees, agents, contractors, Trustees, volunteers or other parties working on behalf of the Organisation handling personal data will be appropriately trained to do so. All employees to attend relevant trainings and workshops aimed at improving knowledge and understanding of the Regulation and how to implement it in their day to day activities. All Employees to ensure that they understand the provisions of the Regulation and understand their responsibilities in relation to personal information that they may process while undertaking their duties.
- All employees, agents, contractors, Trustees, Volunteers, or other parties working on behalf of the Organisation handling personal data will be appropriately supervised;
- All employees, agents, contractors, Trustees, Volunteers, or other parties working on behalf of the Organisation handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise:
-Al files and documents containing personal data held on paper, electronically or otherwise are kept secure at all times and protected against unauthorised, unlawful loss or disclosure.
-All electronic files, documents and emails, computer systems where personal data can be accessed are password protected at all times and in such a manner that the password cannot be easily compromised.
-Employees safely log-out of any systems, networks, apps, laptops other mobile devices if they are to leave such systems unattended for long periods of time and at the end of each working day, to reduce the risk of breach or data hacking.
-All drawers and cabinets containing personal data are securely locked at all times.
-Personal data is not disclosed verbally, in writing, via email, web or any other means accidentally or otherwise to an unauthorised third party.
-All data is collected via approved processes and procedures which have been signed off and approved by the Data Champion (Susan Sinclair).
-Data Champion (Susan Sinclair) is consulted and made aware of any new personal data the member of staff or team intends to collect for any given purpose to ensure these are covered by APWA UK data protection policies and procedures.
-In relation to their own personal data, employees/volunteers/Trustees will ensure that any information provided in connection with their employment is accurate, up-to-date and that they will inform APWA UK of any changes to their circumstances.
-Should the need to take files containing personal data outside the workplace arise, members of staff will be personally responsible for taking reasonable and appropriate precautions to ensure all personal, sensitive and confidential data are taken outside of the work place is secure and kept safe at all times. This includes data in all formats including but not limited to paper and electronic storage such as laptops, tablets and removable storage (eg, USB memory sticks and external drives), mobile phones or any form of networking equipment). Any data loss must be reported immediately to the employee’s line manager who will assess the situation and impact and agree to necessary action.
- Methods of collecting, holding, and processing personal data shall be regularly
evaluated and reviewed;
- All personal data held by the Organisation shall be reviewed periodically.
- The performance of those employees, agents, contractors, Trustees, volunteers or other parties working on behalf of the Organisation handling personal data shall be regularly evaluated and reviewed;
- All employees, agents, contractors, Trustees, volunteers or other parties working on behalf of the Organisation handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract;
- Where any agent, contractor or other party working on behalf of the Organisation
handling personal data fails in their obligations under this Policy that party
shall indemnify and hold harmless the Organisation against any costs, liability,
damages, loss, claims or proceedings which may arise out of that failure.
Transferring Personal Data to a Country Outside the EEA
- The Organisation may from time to time transfer (‘transfer’ includes making
available remotely) personal data to countries outside of the EEA.
- The transfer of personal data to a country outside of the EEA shall take place
only if one or more of the following applies:
-The transfer is to a country, territory, or one or more specific sectors in
that country (or an international organisation), that the European
Commission has determined ensures an adequate level of protection
for personal data;
-The transfer is to a country (or international organisation) which
provides appropriate safeguards in the form of a legally binding
agreement between public authorities or bodies; binding corporate
rules; standard data protection clauses adopted by the European
Commission; compliance with an approved code of conduct approved
by a supervisory authority (e.g. the Information Commissioner’s Office);
certification under an approved certification mechanism (as provided
for in the GDPR); contractual clauses agreed and authorised by the
competent supervisory authority; or provisions inserted into
administrative arrangements between public authorities or bodies authorised by the competent supervisory authority.
-The transfer is made with the informed consent of the relevant data
-The transfer is necessary for the performance of a contract between
the data subject and the Organisation (or for pre-contractual steps taken
at the request of the data subject);
– The transfer is necessary for important public interest reasons;
– The transfer is necessary for the conduct of legal claims;
– The transfer is necessary to protect the vital interests of the data
subject or other individuals where the data subject is physically or
legally unable to give their consent; or
– The transfer is made from a register that, under UK or EU law, is
intended to provide information to the public and which is open for
access by the public in general or otherwise to those who are able to
show a legitimate interest in accessing the register.
Data Breach Notification
APWA UK will notify the ICO as appropriate of its processing of personal data and ensure the updating of the information if there has been a serious breach of Data Protection.
- All personal data breaches must be reported immediately to the Company’s
Data Champion, Susan Sinclair, email@example.com
- If a personal data breach occurs and that breach is likely to result in a risk to
the rights and freedoms of data subjects (e.g. financial loss, breach of
confidentiality, discrimination, reputational damage, or other significant social
or economic damage), the Data Champion (Susan Sinclair) must ensure that the
Information Commissioner’s Office is informed of the breach without delay,
and in any event, within 72 hours after having become aware of it.
- In the event that a personal data breach is likely to result in a high risk to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
- Data breach notifications shall include the following information:
-The categories and approximate number of data subjects concerned;
-The categories and approximate number of personal data records
– The name and contact details of the Organisation’s Data Champion
(or other contact point where more information can be obtained);
-The likely consequences of the breach;
– Details of the measures taken, or proposed to be taken, by the
Organisation to address the breach including, where appropriate,
measures to mitigate its possible adverse effects.
Implementation of Policy
This Policy shall be deemed effective as of May 2018. No part of this Policy
shall have retroactive effect and shall thus apply only to matters occurring on or after