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Bright Clouds

Data Protection Policy

Correcting Data

Individuals have a right to have data corrected if it is wrong, to prevent use which is causing them damage or distress or to stop marketing information being sent to them

Data Collection

Informed consent is when

  • A Data Subject clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data

  • and then gives their consent.

Samr Centre will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form.

When collecting data, Samr Centre will ensure that the Data Subject:

  • Clearly understands why the information is needed

  • Understands what it will be used for and what the consequences are should the Data Subject decide not to give consent to processing

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

  • Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress

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

Data Storage

Information and records relating to service users will be stored securely and will only be accessible to authorised volunteers.

Information will be stored for only as long as it is needed or required statute and will be disposed of appropriately.

It is Samr Centre responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organisation, which has been passed on/sold to a third party.

This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 1998.

Data Subject Access Requests

Members of the public may request certain information from the Local Authority under the Freedom of Information Act 2000. The Act does not apply to Samr Centre. However if at anytime we undertake the delivery of services under contracts with the Local Authority we may be required to assist them to meet the Freedom of Information Act request where we hold information on their behalf.


Samr Centre may need to share data with other agencies such as the local authority, funding bodies and other voluntary agencies.

The Data Subject will be made aware in most circumstances how and with whom their information will be shared.  There are circumstances where the law allows Samr Centre to disclose data (including sensitive data) without the data subject’s consent.  

These are:

  1. Carrying out a legal duty or as authorised by the Secretary of State

  2. Protecting vital interests of a Data Subject or other person

  3. The Data Subject has already made the information public

  4. Conducting any legal proceedings, obtaining legal advice or defending any legal rights  

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

  6. Providing a confidential service where the Data Subject’s consent cannot be obtained or where it is reasonable to proceed without consent: e.g. where we would wish to avoid forcing stressed or ill Data Subjects to provide consent signatures.

Samr Centre regards the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal. 

Samr Centre intends to ensure that personal information is treated lawfully and correctly.


The Samr Centre is the Data Controller under the Act, and is legally responsible for complying with Act, which means that it determines what purposes personal information held will be used for.

The management committee will take into account legal requirements and ensure that it is properly implemented, and will through appropriate management, strict application of criteria and controls:

  • Observe fully conditions regarding the fair collection and use of information,

  • Meet its legal obligations to specify the purposes 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 any legal requirements,

  • Ensure the quality of information used,

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

    • The right to be informed that processing is being undertaken

    • The right of access to one’s personal information

    • The right to prevent processing in certain circumstances and

    • The right to correct, rectify, block or erase information which is regarded as wrong 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

Data Protection Manager - Sami Ullah (Secretary) 

The Data Protection Officer will be responsible for ensuring that the policy is implemented and will have overall responsibility for:

  • Everyone processing personal information understands that they are contractually responsible for following good data protection practice

  • Everyone processing personal information is appropriately trained to do so

  • Everyone processing personal information is appropriately supervised

  • Anybody wanting to make enquiries about handling personal information knows what to do

  • Dealing promptly and courteously with any enquiries about handling personal information

  • Describe clearly how it handles personal information

  • Will regularly review and audit the ways it hold, manage and use personal information

  • Will regularly assess and evaluate its methods and performance in relation to handling personal information 

  • All  staff and volunteers are aware that a breach of the rules and procedures identified in this policy may lead to action being taken against them

This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 1998.

In case of any queries or questions in relation to this policy please contact the Samr Centre Data Protection Officer.

Destroying Data

Personal data should only be kept for as long as it is needed i.e. only keep that data for the duration of administering the campaign/project and securely dispose of once the promotion and monitoring period is complete.   If a customer is housebound and receives regular visits from a volunteer – ensure the list is securely stored and remove customer details when they change or the customer no longer receives the service.  Review the list annually. We will ensure that this information is confidentially destroyed at the end of the relevant retention period.

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