1. Data Protection Principles

The BGTA, a Recognised Tenants’ Association under section 29 of the Landlord and Tenant Act 1985, is committed to processing data in accordance with its responsibilities under the UK General Data Protection Regulation (GDPR). 

The principles set out in the GDPR requires that personal data shall be:

• processed in relation to that person;

• collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those 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;

• 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; and

• 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.

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2. General provisions:

• This policy applies to all personal data processed by the BGTA. 

• The Committee of the BGTA shall take responsibility for the BGTA’s ongoing compliance with this policy. 

• This policy shall be reviewed at least every 3 years. 

• If necessary at any time, the BGTA shall register with the Information Commissioner’s Office as an organisation that processes personal data. 

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3. Lawful, fair and transparent processing:

• To ensure its processing of data is lawful, fair and transparent, the BGTA shall maintain a register of all the ways in which data is collected and stored (Register of Systems). 

• The Register of Systems shall be reviewed at least annually. 

• Individuals have the right to access their personal data and any such requests made to the BGTA shall be dealt with in a timely manner. 

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4. Lawful purposes:

• All data processed by the BGTA must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see https://ico.org.uk for more information). 

• The BGTA 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 the BGTA’s systems.  

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5. Archiving / removal:

• To ensure that personal data is kept for no longer than necessary, the BGTA shall put in place an archiving policy for each area in which personal data is processed and review this process annually. 

• The archiving policy shall consider what data should/must be retained, for how long, and why. 

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6. Security:

• The BGTA shall ensure that personal data is stored securely using modern software that is kept up to date.  

• 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. 

• When personal data is deleted, this should be done safely such that the data is irrecoverable. 

• Appropriate back-up and disaster recovery solutions shall be in place. 

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7. 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 BGTA shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the Information Commissioner’s Office.