(Last updated 23- May -18)


1. Data protection principles


Forst & Onyx is committed to processing data in accordance with its responsibilities under the General Data Protection Regulation (GDPR).


Article 5 of the GDPR requires that personal data shall be:


  • processed lawfully, fairly and in a transparent manner in relation to individuals;


  • 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;


  • adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;


  • 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;


  • 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; and


  • 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.


2. General provisions


This policy applies to all personal data processed by Forst & Onyx.


Forst & Onyx only collects and processes personal data of supporters for the purposes of activity to which they have actively consented.


The Responsible Person shall take responsibility for Forst & Onyx’s ongoing compliance with this policy.


This policy shall be reviewed at least annually.


Forst & Onyx shall register with the Information Commissioner’s Office as an organisation that processes personal data.


3. Lawful, fair and transparent processing


To ensure its processing of data is lawful, fair and transparent, Forst & Onyx will store and maintain personal data only on GDPR-compliant systems.


Individuals have the right to access their personal data and any such requests made to Forst & Onyx shall be dealt with in a timely manner.


4. Lawful purposes


All data processed by Forst & Onyx must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).


Forst & Onyx shall note the appropriate source of lawful basis in its personal data register.


Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.


Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in Forst & Onyx’s systems.


5. Data minimisation


Forst & Onyx shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.


6. Accuracy


Forst & Onyx shall take reasonable steps to ensure personal data is accurate.


Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.


7. Archiving / removal


To ensure that personal data is kept for no longer than necessary, Forst & Onyx shall consider what data should/must be retained, for how long, and why.


In respect of supporters of Forst & Onyx, personal data for the purposes of Charity communications shall be retained until opt-in consent has been revoked by the relevant individual or, in the absence of such revocation, removed upon review by Forst & Onyx where it is considered that the personal data is no longer necessary for Forst & Onyx’s purposes or activities.


8. Security


Forst & Onyx shall ensure that personal data is stored securely using modern software that is kept-up-to-date.


Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.


When personal data is deleted this should be done safely such that the data is irrecoverable.


Appropriate back-up and disaster recovery solutions shall be in place.


9. Breach


In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Forst & Onyx shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website