Community TV Trust [CTVT] upholds UK law in respecting privacy of the individual and the need for CTVT’s compliance. CTVT will only hold contact details and if necessary and relevant, job description/ professional capacity, prime reason for contact with CTVT being initiated.
We will carefully store any personal data. This aspect of GDPR is overseen by our Data Protection Officer (DPO) who is currently Dermot Trimble. If Mr Trimble is unavailable then Chris Haydon will deal with any matters that arise.
Principles: Community TV Trust entirely accepts the spirit of UK GDPR and will always and robustly seek to demonstrate its compliance.
Seven key principles lie at the heart of the general data protection regime. Personal data shall be:
“(a) processed lawfully, fairly and in a transparent manner in relation to individuals (‘lawfulness, fairness and transparency’);
(b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes (‘purpose limitation’);
(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
(d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
(e) 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; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals (‘storage limitation’);
(f) 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 (‘integrity and confidentiality’).”
Article 5(2) adds that:
“The controller shall be responsible for, and be able to demonstrate compliance with accountability.”
Data subject rights: The GDPR endows individuals with eight data subject rights.
The right to be informed
CTVT will tell individuals what data is being collected, how it’s being used, how long it will be kept and whether it will be shared with any third parties. This information will be communicated concisely and in plain language.
The right of access
Individuals can submit subject access requests, which will oblige Community TV Trust to provide a copy of any personal data they hold concerning the individual.
CTVT will have one month to produce this information, although there are exceptions for requests that are manifestly unfounded, repetitive or excessive.
The right to rectification
If an individual discovers that the information CTVT holds on them is inaccurate or incomplete, they can request CTVT to update it. CTVT will have one month to do this, and the same exceptions apply.
The right to erasure
Individuals can request CTVT to erase their data in certain circumstances – for example, when the data is no longer necessary, the data was unlawfully processed, or it no longer meets the lawful ground for which it was collected.
This includes instances where the individual withdraws consent.
The right to erasure is also known as ‘the right to be forgotten’.
The right to restrict processing
Individuals can request that CTVT to limits the way it uses personal data.
It’s an alternative to requesting the erasure of data and might be used when an individual contests the accuracy of their personal data.
An individual can also exercise this right when they no longer use the product or service for which it was originally collected, but CTVT needs it to establish, exercise or defend a legal claim.
The right to data portability
Individuals are permitted to obtain and reuse their personal data for their own purposes across different services. This right only applies to personal data that an individual has provided to data controllers by way of a contract or consent.
The right to object
Individuals can object to the processing of personal data that is collected on the grounds of legitimate interests or the performance of a task in the interest/exercise of official authority.
CTVT must stop processing information unless it can demonstrate compelling legitimate grounds for the processing that overrides the interests, rights and freedoms of the individual.
CTVT can also refuse this right if the processing is for the establishment or exercise of defence of legal claims.
Rights related to automated decision making including profiling
The GDPR includes provisions for decisions made with no human involvement, such as profiling, which uses personal data to make calculated assumptions about individuals.
There are strict rules about this kind of processing, and individuals are permitted to challenge and request a review of the processing if they believe the rules aren’t being followed.