By continuing as a member, using our website and services after this date, you agree to these updated terms. If you would like to request further information, you can do so by contacting us at http://naccs.org.uk/contact-us/
NACCS GDPR Policy
This Policy sets out the obligations of the Neuroanaesthesia and Critical Care Society (NACCS), charity number 1094094, whose registered address is 21 Portland Place, London W1B 1PY, regarding retention of personal data collected, held, and processed by the Society in accordance with EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).
The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. The GDPR also addresses “special category” personal data (also known as “sensitive” personal data). Such data includes, but is not necessarily limited to, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation.
Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is
processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, for legal reasons, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data). In addition, the GDPR includes the right to erasure or “the right to be forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:
- Where the personal data is no longer required for the purpose for which it was originally collected or processed;
- When the data subject withdraws their consent;
- When the data subject objects to the processing of their personal data and the Society has no overriding legitimate interest;
- When the personal data is processed unlawfully (i.e. in breach of the GDPR);
- When the personal data needs to be erased to comply with a legal obligation.
The primary aim of this Policy is to set out limits for the retention of personal data and to ensure that those limits, as well as further data subject rights to erasure, are complied with. By extension, this Policy aims to ensure that the Society complies fully with its obligations and the rights of data subjects under the GDPR. In addition to safeguarding the rights of data subjects under the GDPR, by ensuring that excessive amounts of data are not retained by the Society, this policy also aims to improve the speed and efficiency of managing data.
This Policy applies to all personal data held by the NACCS for societal management purposes and by third-party data processors collecting personal data on the Society’s behalf including the AAGBI, Event Management Direct (EMD) and the ebrain organisation, hosted by the Joint Neurosciences Council, which holds and processes data for educational purposes. Personal data is stored in the following ways and in the following locations:
- The Society’s server, hosted by Accent Design Group Ltd, The Studio, Adam & Eve Yard, 94B St Benedicts Street, Norwich NR2 4AB and currently stored in Dublin, Republic of Ireland
- Computers permanently located in the Society address, 21 Portland Place, London W1B 1PY
- Computers permanently located at the offices of EMD, Haywood House, Hydra Business Park, Nether Lane, Sheffield S35 9ZX
- Computers located at the Joint Neurosciences Council for ebrain, Ormond House, 27 Boswell Street, London WC1N 3JZ
- Laptop computers and other mobile devices used by the Society’s Council members.
Data Subject Rights and Data Integrity
All personal data held by the Society is held in accordance with the requirements of the GDPR and data subjects’ rights thereunder. Data subjects are given control over their personal data held by the Company including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of (notwithstanding the retention periods otherwise set by this Data Retention Policy), the right to restrict the Society’s use of their personal data, the right to data portability, and further rights relating to automated decision making and profiling.
Technical and Organisational Data Security Measures
The following technical measures are in place within the Society to protect the
security of personal data:
- Personal data may only be transmitted over secure networks;
- Personal data may not be transmitted over a wireless network if there is a
reasonable wired alternative;
- Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted;
- Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it;
- Where personal data is to be transferred in hardcopy form, it should be passed directly to the recipient or, where that is not possible, sent using Royal Mail;
- All personal data transferred physically should be transferred in a suitable container marked “confidential”;
- No personal data may be shared informally;
- All hardcopies of personal data, along with any electronic copies stored on physical media should be stored securely;
- No personal data may be transferred to other parties, whether such parties are working on behalf of the Society or not, without authorisation from Council;
- Personal data must be handled with care at all times and should not be left unattended or on view;
- Computers used to view personal data must always be locked before being left unattended;
- All electronic copies of personal data should be stored securely using passwords and encryption;
- All passwords used to protect personal data should be changed regularly and must be secure;
- Under no circumstances should any passwords be written down or shared;
- All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably possible after becoming available;
The following organisational measures are in place within the Society to protect the security of personal data:
- All Council members and other parties working on behalf of the Society shall be made fully aware of both their individual responsibilities and the Society’s responsibilities under the GDPR and under the Society’s Data Protection Policy;
- Only Council members and other parties working on behalf of the Society that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Society;
- All Council members and other parties working on behalf of the Society handling personal data will be appropriately trained to do so or appropriately supervised;
- All Council members and other parties working on behalf of the Society handling personal data should exercise care and caution when discussing any work relating to personal data at all times;
- Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
- The performance of those working on behalf of the Society handling personal data shall be regularly evaluated and reviewed;
- All agents, contractors, or other parties working on behalf of the Society handling personal data must ensure that any and all relevant employees are held to the same conditions as those of the Society arising out of the GDPR and the Society’s Data Protection Policy;
- Where any agent, contractor or other party working on behalf of the Society handling personal data fails in their obligations under the GDPR and/or the Society’s Data Protection Policy, that party shall indemnify and hold harmless the Company against any costs, liability.
Upon expiry of the data retention periods set out below or when a data subject exercises their right to have their personal data erased, personal data shall be deleted, destroyed, or otherwise disposed of.
As stated above, and as required by law, the Society shall not retain any personal data for any longer than is necessary in light of the purpose for which that data is collected, held, and processed. Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below. When establishing and/or reviewing retention periods, the following shall be taken into account:
- The objectives and requirements of the Society;
- The type of personal data in question;
- The purpose for which the data in question is collected, held, and processed;
- The category or categories of data subject to whom the data relates.
If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria. Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Society to do so (whether in response to a request by a data subject or otherwise). In limited circumstances, it may also be necessary to retain personal data for longer periods where such retention is for archiving purposes that are in the public interest, for scientific or historical research purposes, or for statistical purposes. All such retention will be subject to the implementation of appropriate technical and organisational measures to protect the rights and freedoms of data subjects, as required by the GDPR.
Useful Documents and links:
Accent Design Statement: Accent GDPR Readiness Statement
ebrain GDPR Statement: Ebrain GDPR
Event Management Direct GDPR Statement: EMD DATA RETENTION POLICY