Airgem DeltaLtd

General Data Protection Regulation Policy

1. Introduction

Airgem Delta Ltd needs to collect and use certaintypes of information about the Individual or Service User who come into contact with inorder to carry out our work. This personal information must be collected and dealt with appropriately whetherit is collected on paper, stored ina computer database, or recorded on other materialand there are safeguards to ensurethis under the General Data Protection Regulation (GDPR) 2016.

2. Data Controller / Processor

Airgem Delta Ltd is the Data Controller under the Act, which means that it determines what purposes personal information held, will be used for. Itis also responsible for notifying the Information Commissioner of the data it holds oris likely to hold, and thegeneral purposes that this data will be used for. It also process’s data which includes collecting, storing and managingdata.

3. Disclosure

Airgem Delta Ltd may have to share data with other agenciessuch as the local authority, funding bodies and other voluntaryagencies.

The Individual/Service User will be asked forconsent and made aware how and with who, their information will be shared.There are circumstances where the law allows Airgem Delta Ltd to disclose data (including sensitive data) without the datasubject’s consent.

These are:

a)   Carrying out a legal duty

b)   Protecting vital interests of an Individual/Service User or other person c)    The Individual/Service User has already made the information public

d)   Conductingany legal proceedings, obtaining legaladvice or defending any legal rights

e)   Monitoring for equal opportunities purposes – i.e. race, disability or religion

f)     Providing a confidential service where the Individual/Service User’s consent cannot be obtained or where it is reasonable toproceed without consent: e.g. wherewe would wish to avoid forcing stressed or ill Individuals/Service Users to provide consent signatures.

Airgem Delta Ltd regards the lawful and correct treatmentof personal information as very important to successful working, and to maintaining the confidence of those with whom we deal.

Airgem Delta Ltd intendsto ensure that personal information is treated lawfully and correctly. To this end, Airgem Delta Ltd will adhereto the Principles of Data Protection, as detailed in the

General Data Protection Regulation (GDPR) 2016.

Specifically, the Principles requirethat personal information:

a)   Shall be processed fairly and lawfully and, shall not be processed unless specific conditions are met,

b)   Shall beobtained only for one or more of the purposes specified in the Act, and shall not beprocessed in any manner incompatible with that purpose or those purposes,

c)    Shall be adequate, relevant and not excessive in relation to those purpose(s)

d)   Shall be accurate and, where necessary, kept up to date, e)   Shall notbe kept for longer than is necessary

f)    Shall be processed in accordance with the rights of data subjects under the Act,

g)   Shall be kept secure and take appropriate technical and other measureto prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal information,

h)   Shall not be transferred toa 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 Individuals/Service Users in relation to the processingof personal information.

Airgem Delta Ltd, 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 purpose for which information is used.

·    Collect and process appropriate information, and only to the extent that it is needed to fulfil its operational needs or to comply with anylegal requirements.

·    Ensure that the rights of people about whom information is held, can be fully exercised under the Act. These include:

o The right to be informed that processingis being undertaken,

o The right of access to one’s personal information

o The right to prevent processing in certain circumstances and

o  The right to correct, rectify, block or erase information which is regarded aswrong information.

·    Take appropriate technical and organisational security measures to safeguard personal information

·    Ensure that personal information is not transferred abroad without suitable safeguards

·    Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information

·    Set out clear procedures for responding to requests for information.

4. Data Collection

Informed consent is when

·    An Individual/Service User clearly understands why their information is needed, who it will beshared with, and the possible consequences of them agreeing or refusing the proposed use of the data and then gives their consent.

Airgem Delta Ltd will ensure that data iscollected within the boundaries defined in this policy. This applies to data that iscollected in person, or by completing a form.

When collecting data, Airgem Delta Ltd will ensure that the

Individual/Service User:

a)   Clearly understands why the information is needed

b)   Understands what it will be used for and what the consequencesare should the

Individual/Service User decide not to give consent to processing

c)    As far as reasonably possible, grants explicit consent, either written or verbal for data to be processed

d)   Is, as far as reasonably practicable, competent enough to give consent and has given so freelywithout and duress.

e)   Has received sufficient information on why their data is needed and how it will be used.