This is a statement of the data protection policy adopted by Equal Adventure (EA). The policy is subject to regular review to reflect, for example, changes to legislation or to the structure or policies of EA. All staff are expected to apply the policy and to seek advice when required.
Equal Adventure needs to collect and use certain types of information about people with whom it deals in order to operate. These include past and prospective staff, EA’s own employees, customers, contract workers and others with whom EA conducts business. In addition, EA may occasionally be required by law to collect and use certain types of information to comply with the requirements of government departments. This personal information must be dealt with properly however it is collected, recorded and used – whether on paper, electronically, or other means.
We regard the lawful and correct treatment of personal information by Equal Adventure as important to the achievement of our objectives and to the success of our operations, and to maintaining confidence between those with whom we deal and ourselves. We therefore need to ensure that EA treats personal information lawfully and correctly.
Equal Adventure will ensure that personal information:
1. shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met
2. shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes
3. shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed
4. shall be accurate and, where necessary, kept up to date
5. shall not be kept for longer than is necessary for the specified purpose(s)
6. shall be processed in accordance with the rights of data subjects under the Act
7. should be subject to appropriate technical and organisational measures to prevent the unauthorised or unlawful processing of personal data, or the accidental loss, destruction, or damage to personal data
8. shall be accessed only by those authorised and with reason to have access
9. shall not be transferred to any other individual or organisation.
Therefore, Equal Adventure will, through appropriate management and strict application of criteria and controls:
- observe fully conditions regarding the fair collection and use of information
- meet its legal obligations to specify the purposes for which information is used
- collect and process appropriate information only to the extent that it is needed to fulfil our operational needs or to comply with any legal requirements
- ensure the quality of information used
- ensure that the information is held for no longer than is necessary
- ensure that the rights of people about whom information is held can be fully exercised under legislation (i.e. the right to be informed that processing is being undertaken, to access one’s personal information; to prevent processing in certain circumstances, and to correct, rectify, block or erase information that is regarded as wrong information)
- take appropriate technical and organisational security measures to safeguard personal information
- ensure that personal information is not transferred unless legally bound to do so.
Equal Adventure has documented within its systems what personal data it holds, where it came from, with whom it is shared and what we do with it.
Equal Adventure will continue to hold information relating to all sales of equipment and training, and participants on outdoor courses, for the duration of the business for the purpose of:
- equipment – traceability for equipment failure or misuse
- training – validation of attendance and/or certification
- outdoor course participants – accurate evidence for/against claims of insult or injury to protect participants, staff and the organisation
- outdoor course venues and contractors.
Should there be a breach in data Equal Adventure will notify the information commissioner within 72 hours, providing them with:
- what has happened, including:
- whether it is theft or fraud
- any financial loss or damage of reputation
- what we are doing about it
- whether we did something prior to the breach that may have caused the breach
- the organisation’s data protection leader.
This Policy should be read in association with the Information Security Policy.
This Policy has been reviewed and updated in line with the General Data Protection Regulation (GDPR), May 2018.