Policy Statement
German Grocery collects and uses information about people with whom it communicates.
This personal information must be dealt with properly and securely however it is collected, recorded and used – whether on paper, in a computer, or recorded on other material – and there are safeguards to ensure this in the Data Protection Act 1998.

German Grocery regards the lawful and correct treatment of personal information as very important to the successful and efficient performance of its functions, and to maintain confidence between those with whom it deals.
To this end German Grocery fully endorses and adheres to the Principles of Data Protection, as set out in the Data Protection Act 1998.

The purpose of this policy is to ensure that the staff, volunteers and trustees of German Grocery are clear about the purpose and principles of Data Protection and to ensure that it has guidelines and procedures in place which are consistently followed.
Failure to adhere to the Data Protection Act 1998 is unlawful and could result in legal action being taken against Organisation Name or its staff, volunteers or trustees.

The Data Protection Act 1998 regulates the processing of information relating to living and identifiable individuals (data subjects). This includes the obtaining, holding, using or disclosing of such information, and covers computerised records as well as manual filing systems and card indexes.
Data users must comply with the data protection principles of good practice which underpin the Act.
To comply with the law, information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully.

To do this German Grocery follows the eight Data Protection Principles outlined in the Data
Protection Act 1998, which are summarised below:

I.     Personal data will be processed fairly and lawfully
II.    Data will only be collected and used for specified purposes
III.   Data will be adequate, relevant and not excessive
IV.   Data will be accurate and up to date
V.    Data will not be held any longer than necessary
VI.   Data subject’s rights will be respected
VII.  Data will be kept safe from unauthorised access, accidental loss or damage
VIII. Data will not be transferred to a country outside the European Economic Area, unless that
       country has equivalent levels of protection for personal data.

The principles apply to “personal data” which is information held on computer or in manual filing systems from which they are identifiable. German Grocery employees who process or use any personal information in the course of their duties will ensure that these principles are followed at all times.

The following procedures have been developed in order to ensure that German Grocery meets it’s responsibilities in terms of Data Protection. For the purposes of these procedures data collected, stored and used by German Grocery, falls into 2 broad categories:

1. German Grocery internal data records; Staff, volunteers and trustees
2. German Grocery external data records; Members, customers, clients.

German Grocery as a body is a DATA CONTROLLER under the Act, and the Executive Committee is ultimately responsible for the policy’s implementation.

External data records

German Grocery obtains personal data (such as names, addresses, and phone numbers) from members/clients. This data is obtained, stored and processed solely to assist staff and volunteers in the efficient running of services. Personal details supplied are only used to send material that is potentially useful. Most of this information is stored on the organisation’s database.

German Grocery obtains personal data and information from clients and members in order to provide services. This data is stored and processed only for the purposes outlined in the agreement and service specification signed by the client/ member.

Personal data is collected over the phone and using other methods such as e-mail. During this initial contact, the data owner is given an explanation of how this information will be used. Written consent is not requested as it is assumed that the consent has been granted when an individual freely gives their own details.
Personal data will not be passed on to anyone outside the organisation without explicit consent from the data owner unless there is a legal duty of disclosure under other legislation, in which case the Director will discuss and agree disclosure with the Chair/ Vice Chair. Contact details held on the organisation’s database may be made available to groups/ individuals outside of the organisation. Individuals are made aware of when their details are being collected for the database and their verbal or written consent is requested.

Only the organisation’s staff, volunteers and trustees will normally have access to personal data. All staff, volunteers and trustees are made aware of the Data Protection Policy and their obligation not to disclose personal data to anyone who is not supposed to have it. Information supplied is kept in a secure filing, paper and electronic system and is only accessed by those individuals involved in the delivery of the service. Information will not be passed on to anyone outside the organisation without their explicit consent, excluding statutory bodies e.g. the Inland Revenue. Individuals will be supplied with a copy of any of their personal data held by the organisation if a request is made.
All confidential post must be opened by the addressee only.

German Grocery will take reasonable steps to keep personal data up to date and accurate. Personal data will be stored for as long as the data owner/ client/ member uses our services and normally longer. Where an individual ceases to use our services and it is not deemed appropriate to keep their records, their records will be destroyed according to the schedule in Appendix B. However, unless we are specifically asked by an individual to destroy their details, we will normally keep them on file for future reference.

If a request is received from an organisation/ individual to destroy their records, we will remove their details from the database and request that all staff holding paper or electronic details for the organisation destroy them. This work will be carried out by the Information Officer. This procedure applies if Organisation Name is informed that an organisation ceases to exist.

Personal data may be kept in paper-based systems and on a password-protected computer system. Paper-based data are stored in organised and secure systems.
German Grocery operates a clear desk policy at all times.

Use of Photographs
We don't ask our clients and customers for photographs.

Criminal Records Bureau
German Grocery will act in accordance with the CRB’s code of practice. Copies of disclosures are kept for no longer than is required. In most cases this is no longer than 6 months in accordance with the CRB Code of Practice. There may be circumstance where it is deemed appropriate to exceed this limit e.g. in the case of disputes.

Responsibilities of staff, volunteers and trustees
During the course of their duties with German Grocery staff, volunteers and trustees will be dealing with information such as names/addresses/phone numbers/e-mail addresses of members/clients/volunteers. They may be told or overhear sensitive information while working for German Grocery The Data Protection Act (1988) gives specific guidance on how this information should be dealt with. In short to comply with the law, personal information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully. Staff, paid or unpaid must abide by this policy. To help staff, volunteers, trustees meet the terms of the Data Protection Act; the attached Data Protection/Confidentiality statement has been produced. Staff, volunteers and trustees are asked to read and sign this statement to say that they have understood their responsibilities as part of the induction programme.

Compliance with the Act is the responsibility of all staff, paid or unpaid. German Grocery will regard any unlawful breach of any provision of the Act by any staff, paid or unpaid, as a serious matter which will result in disciplinary action. Any employee who breaches this policy statement will be dealt with under the disciplinary procedure which may result in dismissal for gross misconduct. Any such breach could also lead to criminal prosecution. Any questions or concerns about the interpretation or operation of this policy statement should in the first instance be referred to the line manager.

Retention of Data
No documents will be stored for longer than is necessary. For guidelines on retention periods see the Data Retention Schedule. All documents containing personal data will be disposed of securely in accordance with the Data Protection principles.


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