Data Protection Policy

1.Policy StatementRBKares is committed to processing data in accordance with it’s responsibilities under the General Data Protection Regulations (GDPR). Article 5 of the GDPR requires that personal data shall be: processed lawfully, fairly and in a transparent manner in relation to individuals; collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes; adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed; accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay; 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 subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and processed in a manner that ensures appropriate security of the personal data, including 2 protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
2.General ProvisionsThis policy applies to all personal data processed by RBKares. The Responsible Person will be answerable for ongoing compliance with this policy. This policy shall be reviewed annually.  RBKares shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3.Lawful, fair and transparent processingTo ensure its processing of data is lawful, fair and transparent, RBKares shall maintain a Register of Systems. The Register of Systems shall be reviewed annually. Individuals have the right to access their personal data and any such requests made to RBKares shall be dealt with in a timely manner.
4.Lawful purposesAll data processed by RBKares must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information). RBKares shall note the appropriate lawful basis in the Register of Systems. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in RBKare’s systems.
5.Data minimisationRBKares shall ensure that personal data is adequate, relevant and limited to what is necessary for the purpose.
6.AccuracyRBKares shall take reasonable steps to ensure personal data is accurate and up to date.
7.Archiving and removalRBKares will ensure that personal data is archived or removed when no longer required. The archiving policy shall consider what data should  or must be retained, for how long and why.
8.SecurityRBKares shall ensure that personal data is stored securely using current modern software. Access to personal data shall be limited to those that need access and appropriate security to avoid unauthorised information sharing. When personal data is deleted, this should be done safely so that the data is irrecoverable. Appropriate back-up and disaster recovery solutions shall be in place.
9.BreachIn the event in a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, RBKares shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website)
Approved by:Kate Kenyon, Sara Grimshaw, Sam Lord, Ady Gomersall
Approval date:21st October 2021
Next formal review:21st October 2022