Divine Days CIC Data Protection Policy
What This Policy Covers
This policy details your rights and obligations in relation to your personal data and the personal data of third parties.
“Personal data” is any information that relates to a living individual who can be identified from that information.
“Processing” is any use that is made of personal data, including collecting, storing, amending, disclosing or destroying it.
“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or political beliefs, trade union membership, health, sex life or sexual orientation and biometric data. “Criminal records data” means information about an individual’s criminal convictions and offences and information relating to criminal allegations and proceedings.
If you have access to the personal, special categories or criminal records data of employees or of third parties, you must comply with this Policy.
Data Protection principles
Divine Days CIC processes personal data in accordance with the following data protection principles:
- Divine Days CIC processes personal data lawfully, fairly and in a transparent manner;
- Divine Days CIC collects personal data only for specified, explicit and legitimate purposes;
- Divine Days CIC processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of the processing;
- Divine Days CIC keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay;
- Divine Days CIC retains personal data only for the period necessary for the processing;
- Divine Days CIC adopts appropriate measures to make sure that personal data is secure and is protected against unauthorised or unlawful processing and from accidental loss, destruction or damage.
Data protection legislation prescribes the way in which Divine Days CIC may collect, retain and handle personal data. Divine Days CIC will comply with the requirements of data protection legislation and all employees and contractors who handle personal data in the course of their work must also comply with it.
Divine Days CIC will inform individuals of the reasons for processing their personal data, how it uses such data and the legal basis for processing. It will not process personal data about individuals for other reasons.
Where Divine Days CIC processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with the rules relating to special categories of data and criminal records data.
Divine Days CIC will update personal data promptly if an individual advises that their information has changed or is inaccurate.
Personal data gathered during the employment or engagement of an employee, worker, contractor, volunteer, or intern is held in the individual’s personal file (in hard copy or electronic format, or both), and on HR systems. The periods for which Divine Days CIC holds personal data are contained in its privacy notices.
Access to your personal data [subject access requests]
You have the right to make a subject access request. If you make such a request, Divine Days CIC will tell you:
- whether or not your data is processed and if so why; the categories of personal data concerned and the source of the data if it is not collected from you;
- to whom your data may be disclosed, including any recipients located outside the European Economic Area (EEA) and the safeguards that apply to any such transfers;
- for how long your personal data is stored or how that period is decided;
- your rights to rectification or erasure of data, or to restrict or object to processing;
- your right to complain to the Information Commissioner if you think Divine Days CIC has failed to comply with your data protection rights; and
- whether or not Divine Days CIC carries out any automated decision-making and the logic involved in such decision-making.
Divine Days CIC will also provide you with a copy of the personal data undergoing processing. This will normally be in electronic form if you have made the request electronically, unless you request otherwise.
If you want additional copies, Divine Days CIC will charge a fee, which will be based on the administrative cost of providing the additional copies.
You have a number of other rights in relation to your personal data. You can require Divine Days CIC to:
- rectify inaccurate data;
- stop processing or erase data if your interests override Divine Days CIC’s legitimate grounds for processing data (where Divine Days CIC relies on its legitimate interests as a lawful basis for processing data);
- stop processing or erase data if it is unlawful; and
- stop processing data for a period if it is inaccurate or if there is a dispute about whether or not your interests override Divine Days CIC’s legitimate interests for processing the data.
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