Privacy Policy

Preston Community Library is not required to register with the Information Commissioner’s Office (ICO) under the Data Protection Act. 

General Statement of the Preston Community Library’s Duties and Scope 

Preston Community Library is required to process relevant personal data regarding members of staff, volunteers, and members as part of its operation and shall take all reasonable steps to do so in accordance with this Policy. 

Data Protection Controller 

The Library ‘Chair’ and ‘Committee’ acting as the Data Protection Controller (DPC) who will endeavour to ensure that all personal data is processed in compliance with this Policy and the Principles of the Data Protection Act 1998. The Freedom of Information Act 2000 and the Protection of Freedoms Act 2012 are also relevant to parts of this policy. 

The Library recognises The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) adopted 27 April 2016, the two-year transition period and the application date of 25 May 2018 and is actively working towards compliance with that directive. 

The Principles 

The Library shall so far as is reasonably practicable comply with the Data Protection Principles (the Principles) contained in the Data Protection Act to ensure all data is:- 

  • Fairly and lawfully processed 
  • Processed for a lawful purpose 
  • Adequate, relevant and not excessive 
  • Accurate and up to date 
  • Not kept for longer than necessary 
  • Processed in accordance with the data subject’s rights 
  • Secure 
  • Not transferred to other countries without adequate protection 

Definitions 

  • The Library is ‘Preston Community Library’, is a registered Charity Limited by guarantee where the Data Protection Act applies. 
  • Parental consent, includes the consent of a guardian. 
  • Data Subject, an individual who is the subject of the personal data. 

Personal Data 

Personal data covers both facts and opinions about an individual where that data identifies an individual. For example, it includes contact information necessary for engagement such as the volunteers’s name and address and may require details for reimbursement of expenses. Personal data may also include sensitive personal data as defined in the Act.

Processing of Personal Data

Consent may be required for the processing of personal data unless processing is necessary for the performance of the volunteer’s duties. Any information which falls under the definition of personal data and is not otherwise exempt, will remain confidential and will only be disclosed to third parties with appropriate consent.

Children

Children below the age of consent, consent to process their data and disclose it to parents is implicit until they reach the age of 18. If a child wishes to revoke or change consent they must agree a specific agreement on how their data is to be processed with the data processor.

Photography

The Library may photograph and record activities and events for promotional and fund-raising purposes and may use images and process some personal data (in statistical form only) for direct marketing and fund-raising purposes, data subjects have the right, and will be given the opportunity, to request an opt-out to these activities, which must be respected.

Sensitive Personal Data

Preston Community Library does not generally require to process sensitive personal data. Sensitive personal data includes data relating to medical information, gender, religion, race, sexual orientation, trade union membership and criminal records and proceedings. We will only require to process such information when it pertains to suitability to carry out certain duties.

Rights of Access to Information

Data subjects have the right of access to information held by the Library, subject to the provisions of the Data Protection Act 1998 and the Freedom of Information Act 2000. Any data subject wishing to access their personal data should put their request in writing to the DPO. The Library will endeavour to respond to any such written requests as soon as is reasonably practicable and in any event, within 40 days for access to records and 21 days to provide a reply to an access information request. The information will be imparted to the data subject as soon as is reasonably possible after it has come to the Library’s attention and in compliance with the relevant Acts.

Exemptions

Certain data is exempted from the provisions of the Data Protection Act which includes the following:- 

  • National security and the prevention or detection of crime 
  • The assessment of any tax or duty 
  • Where the processing is necessary to exercise a right or obligation conferred or imposed by law upon the Library, including Safeguarding and prevention of terrorism and radicalisation

The above are examples only of some of the exemptions under the Act. Any further information on exemptions should be sought from the DPC.

Accuracy

The Library will endeavour to ensure that all personal data held in relation to all data subjects is accurate. Data subjects must notify the data processor of any changes to information held about them. Data subjects have the right in some circumstances to request that inaccurate information about them is erased. This does not apply in all cases, for example, where records of mistakes or corrections are kept, or records which must be kept in the interests of all parties to which they apply.

Enforcement

If an individual believes that the Library has not complied with this Policy or acted otherwise than in accordance with the Data Protection Act, the individual should refer their concerns the to the Library ‘Chair’ and ‘Committee’, and if necessary notify the DPC.

Data Security

The Library will take appropriate technical and organisational steps to ensure the security of personal data.

All staff/volunteers will be made aware of this policy and their duties under the Act.

The Library and therefore all staff and volunteers are required to respect the personal data and privacy of others and must ensure that appropriate protection and security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to all personal data.

An appropriate level of data security must be deployed for the type of data and the data processing being performed. In most cases, personal data must be stored in appropriate systems and be encrypted when transported off-site. Other personal data may be for publication or limited publication within the Library, therefore having a lower requirement for data security.

Data Breaches

Any reported breach will be dealt with in a timely and appropriate manner, with further action taken to prevent any reoccurrence.

External Processors

The Library must ensure that data processed by external processors, for example, service providers, Cloud services including storage, web sites etc. are compliant with this policy and the relevant legislation.

Secure Destruction

When data held in accordance with this policy is destroyed, it must be destroyed securely in accordance with best practice at the time of destruction.

Retention of Data

The Library may retain data for differing periods of time for different purposes as required by statute or best practices, individual departments incorporate these retention times into the processes and manuals. Other statutory obligations, legal processes and enquiries may also necessitate the retention of certain data.

The Library may store some data such as registers, photographs, achievements, books and works etc. indefinitely in its archive.

CCTV

The Library operates a CCTV network for the purposes of crime prevention and detection, and Safeguarding.