Moray HandyPerson Services (MHPS) complies with the General Data Protection Regulations (GDPR), effective 25 May 2018.
The lawful basis for processing personal data is legitimate interest and/or consent. MHPS considers that clients and volunteers reasonable expect us to hold personal data in order to process and complete jobs requested by clients.
MHPS does not hold any ‘special categories’ of personal data in electronic form. Some information on toenail clients’ pre-existing conditions is collected to ensure the safe delivery of that service and is held in paper form only.
Responsibilities and Contacts
The Moray HandyPerson Services organisation is the Data Controller.
The manager is the GDPR Advisor within MHPS.
MHPS obtains the minimum amount of personal data for a client including: name; address; and contact details. MHPS might also record relevant information necessary to provide the service safely. For example: ailments such as deafness that mean the client might not hear the doorbell; details of an agency, friend or family member that needs to be contacted to arrange the service or that needs to be present during the service; or, if registered as a client for toenail trimming, conditions that may impact on the safe delivery of that service.
MHPS also creates data that is linked to the client. This includes a record of jobs requested and the outcome of jobs completed.
MHPS may use the information it holds about a client and jobs to:
- Allocate jobs to volunteers
- Simplify the raising of new jobs
- Advise clients about services (this is classed as direct marketing)
- Research needs (any such research will be clearly indicated in any communication with clients)
- Protect the organisation and the volunteers
- Create aggregated statistics (individuals not identified) for statistical purposes as might be required by management, the Board or funders for example.
MHPS keeps records of its volunteers; including:
- Name and contact details
- Skills and preferences
Volunteer information is used:
- To contact volunteers about jobs
- To inform volunteers about the service
MHPS also retains contact information for agencies, companies and organisations that it may need to contact in the normal course of business.
MHPS only wants to hold accurate and necessary data. As well as the individual’s right to have their data corrected, MHPS requests that clients, volunteers and organisations keep MHPS informed if their details change.
MHPS has careful considered how long personal data should be retained. Many factors have informed this decision; including, in order of weighting:
- Legal requirements
- Insurance requirements
- Contractual obligations including the provision of statistics
- Protection of volunteers
- Protection of the organisation’s reputation
- Nature of the client group
- Frequency of job requests
- Direct marketing opportunities
MHPS will retain client’s personal data for a period of 3 years from the date of their last job or the date they registered to use the service; whichever is the latter. Thereafter, their personal data will be archived for a further period of 3 years. This will be achieved through an annual review so the actual period of data retention may be up to one year longer than stated.
MHPS will immediately archive the records of deceased clients where the organisation has been so notified.
Volunteer records will be archived for 3 years from the date they cease to be volunteers for MHPS.
Any individual for whom MHPS holds personal data may request their data to be deleted at any time. However, MHPS will only accede to such a request after consideration of the informing factors numbered 1 to 5 above; factors 6, 7 and 8 will play no part in the decision. MHPS will keep a record of the rationale leading to decisions on data retention after a request for deletion, for a period of 10 years.
Any concerns about the personal data held on you by the MHPS, or its use, should, in the first instance be addressed to the staff at MHPS. Contact details are:
Moray HandyPerson Services
10 Victoria Crescent
ELGIN IV30 1RQ
The right exists to complain to the Information Commissioner’s Office Scotland if you consider there is a problem with the MHPS handles your data. The ICO Scotland contact details are:
The Information Commissioner’s Office – Scotland
45 Melville Street
EDINBURGH EH3 7HL