Data Management Policy
Policy Last Updated: 23rd May, 2018
The Sherborne Association UK is a non-profit-making registered charity which was formed to continue and promote the work of Veronica Sherborne. The Sherborne Association UK engages in a variety of training and development activities based upon this core purpose. The Sherborne Association UK maintains a membership and our members (including our International Course Leaders) have access to support and materials linked to our core purpose. The Sherborne Association UK engages in marketing activities linked to our core purpose.
As an association, the Sherborne Association UK holds personal data for a variety of reasons linked to our core purpose of the promotion, and development of Sherborne Developmental Movement and the training of individuals and organisations in the practice of Sherborne Developmental Movement.
Types of Data Held
As an association, the Sherborne Association UK holds the following types of personal data (not all data types are collected for each category – data is limited to what is necessary in relation to the purposes for which they are processed and held):
- For members and previous members: names, addresses, dates of birth, email addresses, telephone numbers, places of work.
- For International Course Leaders: names,dates of birth, addresses, email addresses, telephone numbers, places of work, levels of training, dates and locations of training; bank details, qualifications, CV information and and personal statements.
- For organisations and individuals who have received training: names, dates of birth, addresses, email addresses, telephone numbers, places of work, levels, dates and locations of training, invoicing information.
- For committee members: names, dates of birth, addresses, email addresses, telephone numbers, places of work, qualifications, CV information and personal statements.
- For interested parties (who have contacted us through our website; at face-to-face events; via telephone or via email): names, dates of birth, addresses, email addresses, telephone numbers, places of work.
Use of Data
Data collected is used for the purpose for which consent was originally gained. For example, if specific consent is gained to hold personal details on file for the purposes of a training record, this information will not be used for any other purpose. Personal data is used by the Sherborne Association UK for a number of reasons. These include:
- Maintenance of a training record so that the Sherborne Association UK are able to check that individuals meet the requirements for progression to the next level of training; to confirm that an individual has been trained and at which level.
- Sharing of information about upcoming training and development events, opportunities and activities (either run directly by the Sherborne Association UK; by our sister international organisations; by other organisations with similar purposes (such as the Laban Guild) or by our independent International Course Leaders)
- A record of our members, which is used for purposes linked to membership, including the sending of the ‘In Touch’ newsletter; reminders about membership renewal; CPD updates and information about the work of the Sherborne Association and developments in Sherborne Developmental Movement; training opportunities.
- Information required to process payments and to send invoices for training and development work which have been provided with consent by individuals and by organisations.
- The Sherborne Association UK hold personal information (including bank details) for our ICLs and with consent, some information is included on our website to allow interested parties to contact ICLs directly.
- The Sherborne Association UK collects names and telephone numbers for emergency contacts for individuals in case of medical emergency during training or development activities. The Sherborne Association UK does not take this information away from the venue and representatives hand these forms back to attendees at the end of the training course.
- The Sherborne Association UK passes personal data on to International Course Leaders where the Sherborne Association UK have gained consent to do so in order to arrange training for interested parties.
Data Shared with and by International Course Leaders and Sherborne Developmental Movement Practitioners
International Course Leaders and Practitioners are not employed by the Sherborne Association UK and are freelance trainers and practitioners and are therefore responsible for their own policies and procedures, including data management policies. The Sherborne Association UK takes no responsibility for individual practitioners’ data management policies or International Course Leaders’ data management policies. However, when communicating, sharing and reporting personal data with the Sherborne Association UK directly, ICLs must follow our agreed policies. Data will only be shared where explicit consent has been gained.
The Sherborne Association UK passes personal data on to International Course Leaders where explicit consent has been gained to do so for the purposes of arranging training for interested parties.
Prior to May 2018, the Sherborne Association UK holds some personal data (training records including names, addresses, dates of birth, places of work, email addresses, telephone numbers) in chronologically ordered sets of manual records. The association is working towards holding all personal data electronically. In the interim, our chronologically ordered sets of manual records are stored securely and will only be used for their original intended purposes (training records).
Storage of Data
In accordance with GDPR regulations, personal data is processed in a manner that ensures appropriate security of the personal data. Digitally held data is stored securely and access is limited to those who require it in order to pursue the intended purposes. Manually held data is stored using appropriate physical storage solutions.
The Sherborne Association UK will actively gain consent to use personal data before the data is used or stored in any way. This is an ‘opt in’ service and individuals can refuse consent without detriment to the service provided where this is possible (for example, the Sherborne Association UK will make individuals aware that if the Sherborne Association UK are not given permission to hold their data for our training records, the Sherborne Association UK will not be able to verify their training status at a later date). The Sherborne Association UK will inform individuals about our procedures and their rights in regards to the use of storage of their personal data at the time of gaining consent. In accordance with the GDPR regulations, the Sherborne Association UK will identify our purposes for processing personal data, our retention periods for that personal data, and who it will be shared with when it is collected.
Any individual can check how their personal data is used and can retract, rectify, restrict or amend their data at any time, or can object to their use of personal data for specific purposes, or manage their preferences by emailing email@example.com. Please note that at present, this is not an automated service and is run by volunteers, so it may take up to one month to amend your changes in accordance with the GDPR regulations. The association is working towards an automated system which will make instant changes for some functions (such as email lists).
Subject Access Requests
Individuals have the right to access their personal data by making a ‘subject access request’ either verbally or in writing. The Sherborne Association UK will respond to a request within one month in accordance with the GDPR regulations. Individuals can make a ‘subject access request’ by emailing firstname.lastname@example.org.
In accordance with the GDPR, personal data breaches will be released to the relevant supervisory authority (ICO) within 72 hours of becoming aware of the breach, where feasible. If the breach is likely to result in a high risk of adversely affecting individuals’ rights and freedoms, the Sherborne Association UK will inform those individuals without undue delay.