Privacy & Data Use Policy


Glenkens Community and Arts Trust Ltd. (GCAT) needs to gather and use certain data about individuals. This policy applies to all projects operated under the auspices of GCAT. The data can be relating to artists, audience, customers, suppliers, business contacts, employees, funders, and other people the organisation has a relationship with or may need to contact. This policy describes how this personal data must be collected, handled and stored to meet the GCAT’s data protection standards and to comply with the law.

This ensures that GCAT:

  • Complies with the latest data protection law and good practice guidelines

  • Protects the rights of staff, patrons, volunteers, user groups, partners etc.

  • Is open about how it stores and processes personal data

  • Protects itself from the risks of a data breach


The General Data Protection Regulations

The new General Data Protection Regulations (GDPR) became law in May 2018 and describes how all organisations must collect, handle and store information. These rules apply regardless of how that data is stored i.e. electronically, on paper or on other materials.


To comply with the law, personal information must be gathered in a certain way and used fairly, stored safely and not disclosed unlawfully.

The GDPR is underpinned by eight important principles. These say that personal data must:


1. Be processed fairly and lawfully

2. Be obtained only for specific, lawful purposes and only for the manner in which it was intended to be used

3. Be adequate, relevant and not excessive

4. Be accurate and kept up to date

5. Not be held for any longer than its intended purpose

6. Processed in accordance with the rights of the people the data is about

7. Be protected by technical and organisational security measures

8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection


Policy Scope

This policy applies to:

• All staff and volunteers of GCAT (NB General reference throughout document to ‘staff’ applies       equally to volunteers, board members etc. who may be carrying out duties on behalf of staff)

• All contractors, suppliers and people working on behalf of GCAT


It applies to all data that GCAT holds relating to identifiable individuals, even if that information technically falls outside of the General Data Protection Regulation. This can include:

• Names of individuals

• Postal addresses

• Email addresses

• Telephone numbers

• Racial or ethnic origin

• Political opinions

• Trade union membership

• Health data

• Sex life or sexual orientation

• Past or spent criminal convictions

• Any other information relating to individuals


The GDPR extends the definition of personal data (from the Data Protection Act 1998) to include:


• Genetic data

• Biometric data

• Location data

• Online Identifiers


Data Protection Risks

This policy helps to protect GCAT from data security risks, including:

• Breaches of confidentiality

e.g. information being given out inadvertently or inappropriately

• Failing to offer choice

   e.g. all individuals should be free to choose how GCAT uses their data relating

• Reputational damage

   e.g. GCAT could suffer if access to sensitive data was hacked or gained illegally



Everyone who works (including volunteers) for or with GCAT has some responsibility for ensuring data is collected, stored and handled appropriately. Each person or project that handles personal data must ensure that it is collected, handled and processed entirely in line with this policy and data protection principles. These people have specific areas of responsibility:

  1. The GCAT Board of Directors is ultimately responsible for ensuring that the company as a whole meets its legal obligations.


  2. The General Manager (Data Protection Officer) is responsible for:

  • Keeping the board updated about data protection responsibilities, risks and issues

  • Reviewing all data protection procedures and related policies in line with an agreed schedule

  • Ensuring an audit of data collection and processing is carried out annually (Privacy Impact Assessment)

  • Arranging data protection training and advice for the people covered by this policy

  • Handling data protection questions from staff and anyone else covered by this policy

  • Dealing with requests from individuals to see the data GCAT holds about them (subject access request)

  • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

  • Maintaining a record of what personal data GCAT holds

  • Ensuring all IT systems, services and equipment used for storing data meet acceptable security standards

  • Performing/instructing regular checks and scans to ensure security hardware and software is functioning properly

  • Evaluating any third-party services GCAT is considering using to store or process data, including cloud services

  • Approving any data protection statements attached to communications such as emails and letters

  • Addressing any data protection queries from journalists or media outlets

  • Working with other staff to ensure marketing initiatives abide by data protection principles


Staff Guidelines

  • The only people able to access data covered by this policy should be those who need it for their work

  • Data should not be shared informally – when access to confidential information is required, employees can request from their line managers

  • GCAT will provide training to all employees to help them understand their responsibilities when handling data

    • Employees should keep all data secure by taking sensible precautions and following the guidelines below

  1. Strong passwords must be used and never shared

  2. Personal data should not be disclosed to unauthorised people either with the company or externally

  3. Data should be regularly reviewed and updated if it is found to be out of date and, if no longer required, should be disposed of

  4. Employees should request help from their line manager or the General Manager if they are unsure about any aspect of data protection

Data Storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the General Manager. When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

  • When not required, the paper or files should be kept in a locked cupboard or filing cabinet

  • Employees should make sure paper and printouts are not left where unauthorised people could see them

  • Data printouts should be shredded and disposed of securely when no longer required

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords that are changed regularly and never shared

  • If data is stored on removable media, these should be kept locked away securely when not being used

  • Data should only be stored on designated drives and servers, and should only be uploaded to a cloud computing service if this has been fully vetted and approved

  • Servers containing personal data should be protected by a strong password

  • Data should be backed up frequently, with backups tested regularly

  • All servers and computers containing data should be protected by an approved security software and a firewall

Use of Data

Personal data is of no value to GCAT unless we can utilise it for the intended purposes, however this is when it is at greatest risk of loss, corruption or theft:

  • When working with any personal data, all employees should ensure the screens of their computers are always blank and locked when left unattended

  • Personal data should not be shared informally, and never sent by email as this form of communication is not secure

  • Data must be encrypted before being transferred electronically

  • Personal data should never be transferred outside of the European Economic Area

  • Employees should not save copies of personal data to their own computers but always access and update the central copy of any data

  • Data breaches are to be reported to the Information Commissioner’s Office (ICO) within 72 hours of discovery

Data Accuracy

The more important it is that the personal data is accurate, the greater the effort GCAT should put into ensuring its accuracy. It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

  • Data will be held in as few places as necessary, staff should not create any additional unnecessary sets

  • Staff responsible for each project should ensure that one definitive contact list is maintained for that project

  • Staff should take every opportunity to ensure data is updated, all obsolete lists should be deleted/destroyed securely

  • GCAT will make it easy for data subjects to update the information GCAT holds about them

  • Data should be updated as soon as any inaccuracies are discovered, and removed if relevant

  • It is the General Manager’s responsibility to ensure the marketing databases are checked every six months


Rights of Individuals

In relation to the data we hold about them, individuals retain rights to:

  • Be informed about what we are doing with data

  • Access their data

  • Correct or modify their data if necessary

  • Erase their data (“right to be forgotten”)

  • Restrict processing

  • Data portability (right to download their data and upload it to a different service provider)

  • Object to our use of their data

Please note that users may withdraw their consent at any time and do not have to give a reason.

Subject Access Requests

If an individual contacts us requesting their data information, this is called a Subject Access Request (SAR). An SAR from individuals should be made by email or letter, addressed to the General Manager.  


The relevant data will be provided within one month. The General Manager will always verify the identity of anyone making a subject access request before handing over any information. All individuals who are the subject of personal data held by GCAT are entitled to:

  • Confirmation that we are processing their data

  • A copy of the personal data we hold on them

  • Any other information we have in our possession about the data subject, such as details of the data we have passed to third parties

Other Reasons for Disclosing Data

In certain circumstances, the General Data Protection Regulation allows personal data to be disclosed to law enforcement agencies with the prior consent of the data subject.  Under these circumstances GCAT will disclose requested data. However, the General Manager will ensure the request is legitimate, seeking assistance from the Board and from GCAT’s legal advisers if necessary.


Providing Information

GCAT aims to ensure that individuals are aware that their data is being processed and that they understand how the data is being used and how to exercise their rights including their right to be forgotten.



We are committed to reviewing our policy and good practice annually.

This policy was last reviewed on 25th May 2018.

Next review due by 25th May 2019.


Brian Edgar

General Manager

Glenkens Community & Arts Trust Ltd

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