Data Protection and Privacy Policies

 

Data Protection Policy

Barnes Children’s Literature Festival Community Interest Company

Definitions

BCLF – means the Barnes Children’s Literature Festival Community Interest Company, a community interest company with charitable aims.

GDPR – means the General Data Protection Regulation.

Responsible Person – means Richard Beal.

Register of Systems – means a register of all systems or contexts in which personal data are processed by the BCLF.

1. Data protection principles

The BCLF is committed to processing data in accordance with its responsibilities under the GDPR. 

Article 5 of the GDPR requires that personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to individuals;
  2. 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;
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. 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;
  5. 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
  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

2. General provisions

  1. This policy applies to all personal data processed by the BCLF;
  2. The Responsible Person shall take responsibility for the BCLF’s ongoing compliance with this policy;
  3. This policy shall be reviewed at least annually; and
  4. The BCLF shall register with the Information Commissioner’s Office as an organisation that processes personal data. 

3. Lawful, fair and transparent processing 

  1. To ensure its processing of data is lawful, fair and transparent, the BCLF shall maintain a Register of Systems;
  2. The Register of Systems shall be reviewed at least annually; and
  3. Individuals have the right to access their personal data and any such requests made to the BCLF shall be dealt with in a timely manner. 

4. Lawful purposes

  1. All data processing by the BCLF must be performed on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests;
  2. The BCLF shall note the appropriate lawful basis in the Register of Systems;
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data; and
  4. 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 the BCLF’s systems.  

5. Data minimisation

The BCLF shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. 

6. Accuracy

  1. The BCLF shall take reasonable steps to ensure personal data is accurate; and
  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data are kept up to date. 

7. Archiving / removal

  1. To ensure that personal data are kept for no longer than necessary, the BCLF shall put in place an archiving policy for each area in which personal data are processed and review this process annually; and
  2. The archiving policy shall consider what data should/must be retained, for how long, and why. 

8. Security

  1. The BCLF shall ensure that personal data are stored securely using modern software that is kept-up-to-date;
  2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information;
  3. When personal data are deleted, this shall be done safely such that the data is irrecoverable; and
  4. Appropriate back-up and disaster recovery solutions shall be in place. 

9. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the BCLF shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the Information Commissioner’s Office (more information on the ICO website). 

Privacy Policies

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User anonymity and personal information

Log files are maintained and analysed of all requests for files on this website’s web servers. Log files do not capture personal information but do capture the user’s IP address, which is automatically recognised by our web servers.

Aggregated analysis of these log files is used to monitor website usage. These analyses may be made to available to Barnes Children’s Literature Festival staff and partner agencies to allow them to measure, for example, overall popularity of the site and typical user paths through the site.

Except as stated already, Barnes Children’s Literature Festival will make no attempt to identify individual users. You should be aware, however, that access to web pages will generally create log entries in the systems of your ISP or network service provider. These entities may be in a position to identify the client computer equipment used to access a page. Such monitoring would be done by the provider of network services and is beyond the responsibility or control of Barnes Children’s Literature Festival.

Barnes Children’s Literature Festival will make no attempt to track or identify individual users, except where there is a reasonable suspicion that unauthorised access to systems is being attempted. In the case of all users, Barnes Children’s Literature Festival reserves the right to attempt to identify and track any individual who is reasonably suspected of trying to gain unauthorised access to computer systems or resources operating as part of Barnes Children’s Literature Festival web services.

As a condition of use of this site, all users must give permission for Barnes Children’s Literature Festival to use its access logs to attempt to track users who are reasonably suspected of gaining, or attempting to gain, unauthorised access.

All log file information collected by Barnes Children’s Literature Festival is kept secure and no access to raw log files is given to any third party.

Use of cookies

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This website does not store any information that would, on its own, allow us to identify individual users of this service without their permission. Any cookies that may be used by this website are used either solely on a per session basis or to maintain user preferences. Cookies are not shared with any third parties.

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Third Party Cookies and Embedded Content

We sometimes embed photos and video content from websites such as YouTube, Vimeo and Flickr. As a result, when you visit a page containing such content, you may be presented with cookies from these websites. We do not control the dissemination of these cookies and you should check the relevant third party’s website for more information.

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