Govanhill Baths Community Trust

Data Protection Policy

1. Context and overview

Govanhill Baths Community Trust (GBCT) needs to gather and use certain information about individuals.
These can include customers, participants, suppliers, business contacts/partners, employees, volunteers and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

Why this policy exists
This data protection policy ensures GBCT:

  • Complies with data protection law and follow good practice including General Data Protection Regulation (GDPR)
  • Protects the rights of staff, participants, volunteers, customers and partners
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risks of a data breach

Data protection law
The Data Protection Act 1998 describes how organisations — including GBCT — must collect, handle and store personal information. From May 2018, GDPR has updated additional rules and guidance along with other ICO guidance produced by the EU’s Article 29 Working Party. The Working Party includes representatives of the data protection authorities from each EU member state, and the ICO is the UK’s representative.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

These regulations are underpinned by eight important principles. These say that personal data must:

  1. Be processed fairly and lawfully
  2. Be obtained only for specific, lawful purposes
  3. Be adequate, relevant and not excessive
  4. Be accurate and kept up to date
  5. Not be held for any longer than necessary
  6. Processed in accordance with the rights of data subjects
  7. Be protected in appropriate ways
  8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

2. People, risks and responsibilities

Policy scope

This policy applies to:

  • The head office of GBCT
  • All social enterprises of GBCT
  • All staff and volunteers of GBCT
  • All members and participants of GBCT
  • All contractors, suppliers and other people working on behalf of GBCT

It applies to all data that GBCT holds relating to identifiable individuals. This can include:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • Plus any other information relating to individuals

Data protection risks

This policy helps to protect GBCT from some very real data security risks, including:

  • Breaches of confidentiality. For instance, information being given out inappropriately.
  • Failing to offer choice. For instance, all individuals should be free to choose how GBCT uses data relating to them.
  • Reputational damage. For instance, GBCT could suffer if hackers successfully gained access to sensitive data.


Everyone who works for or with GBCT has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

  • The Board of Directors is ultimately responsible for ensuring that GBCT meets its legal obligations.
  • The Trust Manager, is responsible for but may appoint relevant staff ( IT or Marketing Manager) to:
    • Keeping the board updated about data protection responsibilities, risks and issues.
    • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
    • Arranging data protection training and advice for the people covered by this policy.
    • Handling data protection questions from staff and anyone else covered by this policy.
    • Dealing with requests from individuals to see the data [company name] holds about them (also called ‘subject access requests’).
    • Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
    • Performing regular checks and scans to ensure security hardware and software is functioning properly.
    • Approving any data protection statements attached to communications such as emails and letters.
    • Addressing any data protection queries from journalists or media outlets like newspapers.
    • Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

    3. General staff guidelines

    • The only people able to access data covered by this policy should be those who need it for their work.
    • Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
    • GBCT will provide training to all employees to help them understand their responsibilities when handling data.
    • Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
    • In particular, strong passwords must be used and they should never be shared.
    • Personal data should not be disclosed to unauthorised people, either within the company or externally.
    • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
    • Employees should request help from their line manager if they are unsure about any aspect of data protection.

    4. Data storage

    These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Trust Manager.

    When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

    These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

    • When not required, the paper or files should be kept in a locked drawer or filing cabinet.
    • Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
    • Data printouts should be shredded and disposed of securely when no longer required.
      When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
    • Data should be protected by strong passwords that are changed regularly and never shared between employees.
    • If data is stored on removable media (like a pen drive or CD), these should be kept locked away securely when not being used.
    • Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
    • Servers containing personal data should be sited in a secure location, away from general office space.
    • Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
    • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
    • All servers and computers containing data should be protected by approved security software and a firewall.

    5. Data use

    Personal data is of no value to GBCT unless we can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

    • When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
    • Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
    • Data must be encrypted before being transferred electronically.
    • Personal data should never be transferred outside of the European Economic Area.
    • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

    6. Data accuracy

    The law requires GBCT to take reasonable steps to ensure data is kept accurate and up to date.

    The more important it is that the personal data is accurate, the greater the effort GBCT should put into ensuring its accuracy.

    It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible:

    • Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
    • Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
    • GBCT will make it easy for data subjects to update the information GBCT holds about them. For instance, via the Trust’s website.
    • Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
    • It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

    7. Subject access requests

    All individuals who are the subject of personal data held by are entitled to:

    • Ask what information GBCT holds about them and why.
    • Ask how to gain access to it.
    • Be informed how to keep it up to date.
    • Be informed how the company is meeting its data protection obligations.

    If an individual contacts GBCT requesting this information, this is called a subject access request.

    Subject access requests from individuals should be made by email, addressed to the data controller, (Data controller is the person assigned with the role of controlling data within the Trust). The data controller can supply a standard request form, although individuals do not have to use this.

    Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 days.

    The data controller will always verify the identity of anyone making a subject access request before handing over any information.

    8. Disclosing data for other reasons

    In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

    Under these circumstances, GBCT Board will decide whether to disclose requested data ensuring the request is legitimate, seeking assistance from the company’s legal advisers where necessary.

    Providing information

    GBCT aims to ensure that individuals are aware that their data is being processed, and that they understand:

    • How the data is being used
    • How to exercise their rights

    This is available on request.