Revised 6th March 2018
Introduction
The Institute of Corrosion (ICorr) is required to maintain certain personal data about living individuals for the purposes of satisfying operational obligations. The Institute recognises the importance of the correct and lawful treatment of personal data; it maintains confidence in the organisation and provides for successful operations.
The types of personal data that the Institute of Corrosion may require include, as examples, information about: current, past and prospective employees and officers of ICorr; members of ICorr; individuals who hold certification where ICorr is the Certificating Body; suppliers and others with whom it communicates. This personal data, whether it is held on paper, on computer or other media, is subject to the appropriate legal safeguards as specified in the Data Protection Act 1998.
The Institute of Corrosion fully endorses and adheres to the eight principles of the Data Protection Act. These principles specify the legal conditions that must be satisfied in relation to obtaining, handling, processing, transportation, and storage of personal data. Employees and any others who obtain, handle, process, transport and store personal data for the Institute must adhere to these principles.
Principles
The principles require that personal data shall:
1. Be processed fairly and lawfully and shall not be processed unless certain conditions are met;
2. Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose;
3. Be adequate, relevant and not excessive for those purposes;
4. Be accurate and, where necessary, kept up to date;
5. Not be kept for longer than is necessary for that purpose;
6. Be processed in accordance with the data subject’s rights;
7. Be kept secure from unauthorised or unlawful processing and protected against accidental loss, destruction or damage by using the appropriate technical and organisational measures;
8. And not be transferred to a country or territory outside the European Economic Area, unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
Satisfaction of principles
In order to meet the requirements of the principles, the Institute of Corrosion shall:
â–ª observe fully the conditions regarding the fair collection and use of personal data;
â–ª meet its obligations to specify the purposes for which personal data is used;
â–ª collect and process appropriate personal data only to the extent that it is needed to fulfil operational or any legal requirements;
â–ª ensure the quality of personal data used;
ICorr, Data Protection Policy (6/3/2018) page 2 of 3
â–ª apply strict checks to determine the length of time personal data is held;
â–ª ensure that the rights of individuals about whom the personal data is held, can be fully exercised under the Act;
â–ª take the appropriate technical and organisational security measures to safeguard personal data;
â–ª and ensure that personal data is not transferred abroad without suitable safeguards.
The Designated Data Protection Officer
The Institute of Corrosion shall ensure compliance with the Data Protection Act by nominating a Data Protection Officer who shall be responsible for implementation of this policy on behalf of the Council, Trustees and President of ICorr. The Data Protection Officer may be contacted at:
Data Protection Officer
The Institute of Corrosion
Barratt House
Kingsthorpe Road
Northampton
NN2 6EZ
tel: + 44 (0)1604 438222
e-mail: admin@icorr.org
Any questions or concerns about the interpretation or operation of this policy should be taken up in the first instance with the Data Protection Officer.
Status of the policy
This policy has been approved by the Council of the Institute of Corrosion and employees of ICorr shall be bound by its principles. Any employee who considers that the policy has not been followed in any way (for example in respect of personal data about themselves or others) should raise the matter with the Data Protection Controller in the first instance.
Subject access
All individuals who are the subject of personal data held by ICorr are entitled to:
â–ª Ask what information ICorr holds about them and why.
â–ª Ask how to gain access to it.
â–ª Be informed how to keep it up to date.
â–ª Be informed what ICorr is doing to comply with its obligations under the 1998 Data Protection Act.
Employee responsibilities
All employees are responsible for:
â–ª Checking that any personal data that they provide to ICorr is accurate and up to date.
â–ª Informing ICorr of any changes to information which they have provided, e.g. changes of address.
â–ª Checking any information that ICorr may send out from time to time, giving details of information that is being kept and processed.
If, as part of their responsibilities, employees collect information about other people (e.g. about the personal circumstances of members, or about individuals in a certification scheme), they must comply with this Policy. ICorr, Data Protection Policy (6/3/2018) page 3 of 3
Data security
The need to ensure that data is kept securely means that precautions must be taken
against physical loss or damage, and that both access and disclosure must be restricted.
All staff are responsible for ensuring that:
â–ª Any personal data which they hold is kept securely
â–ª Personal information is not disclosed either orally or in writing or otherwise to any unauthorised third party.
Rights to access information
All subjects of personal data held by ICorr have the right to access any data that is being kept about them on computer and also have access to paper-based data where it is held on manual filing systems. This right is subject to certain exemptions which are set out in the Data Protection Act. Any person who wishes to exercise this right should make the request in writing to the Data Protection Controller.
The Institute of Corrosion reserves the right to charge a fee payable for each subject access request. If personal details are inaccurate, they shall be amended upon request for no further charge. ICorr aims to comply with requests for access to personal information as quickly as possible, but will ensure that it is provided within 40 days of receipt of a request unless there is good reason for delay. In such cases, the reason for delay will be explained in writing to the individual making the request.
Publications
Information that is in the public domain is exempt from the 1998 Data Protection Act. This would include, for example, information contained within publications. Any individual who has good reason for wishing details in such publications to remain confidential should contact the Data Protection Controller.
Subject consent
The need to process data for normal purposes has been communicated to all data subjects (e.g. members of ICorr). In some cases, if the data is sensitive, for example information about health, race or gender, express consent from the individual to process the data must be obtained.
Retention of data
The Institute of Corrosion shall keep some forms of information for longer than others. All staff are responsible for ensuring that information is not kept for longer than necessary.
Supporting material
The Institute of Corrosion has produced a Data Protection Manual in support of this policy. These documents can be obtained from the Data Protection Controller. The purpose for holding personal data, and a general description of the categories of people and organis-ations to whom it may be disclosed, are listed in the Data Protection Manual as part of the Data Protection register. This information may be inspected or obtained from the Date Protection Controller.
