This policy applies to the processing of personal data in manual and electronic records kept by Lee Abbey International Students’ Club (known as “Lee Abbey London”) in connection with its operation of this international hall of residence for students and its human resources and accounting functions as described below. It also covers Lee Abbey London’s response to any data breach and other rights under the General Data Protection Regulation.
This policy applies to the personal data of accommodation applicants, residents, past residents (alumni) job applicants, existing and former employees, charity workers and self-employed contractors. These are referred to in this policy as relevant individuals.
“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.
“Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).
“Criminal offence data” is data which relates to an individual’s criminal convictions and offences.
“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Lee Abbey London makes a commitment to ensuring that personal data, including special categories of personal data and criminal offence data (where appropriate) is processed in line with GDPR and domestic laws and all its employees conduct themselves in line with this, and other related, policies. Where third parties process data on behalf of Lee Abbey London, Lee Abbey London will ensure that the third party takes such measures in order to maintain Lee Abbey London’s commitment to protecting data. In line with GDPR, Lee Abbey London understands that it will be accountable for the processing, management and regulation, and storage and retention of all personal data held in the form of manual records and on
Personal data is kept in personnel files or within Lee Abbey London’s accommodation booking, HR or payroll systems. The following types of data may be held by Lee Abbey London, as appropriate, on relevant individuals:
Relevant individuals should refer to Lee Abbey London’s privacy notices for more information on the reasons for its processing activities, the lawful bases it relies on for the processing and data retention periods.
All personal data obtained and held by Lee Abbey London will:
In addition, personal data will be processed in recognition of an individuals’ data protection
rights, as follows:
Lee Abbey London has taken the following steps to protect the personal data of relevant individuals, which it holds or to which it has access:
Relevant individuals have a right to be informed whether Lee Abbey London processes personal data relating to them and to access the data that Lee Abbey London holds about them. Requests for access to this data will be dealt with under the following summary guidelines:
Relevant individuals must inform Lee Abbey London immediately if they believe that the data is inaccurate, either as a result of a subject access request or otherwise. Lee Abbey London will take immediate steps to rectify the information.
Lee Abbey London may be required to disclose certain data/information to any person. The circumstances leading to such disclosures include:
These kinds of disclosures will only be made when strictly necessary for the purpose.
Lee Abbey London adopts procedures designed to maintain the security of data when it is stored and transported.
Personal data relating to employees should not be kept or transported on laptops, USB sticks, or similar devices, unless authorised by the Data Protection Officer (Chris Barry).
Where personal data is recorded on any such device it should be protected by:
Failure to follow Lee Abbey London’s rules on data security may be dealt with via Lee Abbey London’s disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.
Lee Abbey London does not transfer personal data to any recipients outside of the UK or EEA, apart from requesting job references from overseas applicants where explicit consent from the applicant has been given.
Where a data breach is likely to result in a risk to the rights and freedoms of individuals, it will be reported to the Information Commissioner within 72 hours of Lee Abbey London becoming aware of it and may be reported in more than one instalment.
Individuals will be informed directly in the event that the breach is likely to result in a high risk to the rights and freedoms of that individual.
If the breach is sufficient to warrant notification to the public, Lee Abbey London will do so without undue delay.
New employees must read and understand the policies on data protection as part of their induction.
All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach.
The nominated data controller/auditors/protection officers for Lee Abbey London are trained appropriately in their roles under the GDPR.
All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and Lee Abbey London of any potential lapses and breaches of Lee Abbey London’s policies and procedures.
Lee Abbey London keeps records of its processing activities including the purpose for the processing and retention periods. These records will be kept up to date so that they reflect current processing activities.
Lee Abbey London’s Data Protection Officer is Chris Barry
He can be contacted at
Lee Abbey London
57-67 Lexham Gardens
email@example.com or 020 72442711