Data Protection Policy
Cambridgeshire and Peterborough Combined Authority (the "CPCA") shall take all necessary steps to ensure that any and all personal data in its possession relating to its suppliers, employees, contactors and all other individuals is processed fairly and lawfully.
The CPCA shall ensure that all relevant statutory requirements are complied with and that it internal data protection procedures and monitored regularly.
The CPCA shall implement and comply with the Data Protection Principles contained in the General Data Protection Regulation ("GDPR") (EU) 2016/679 ("the Act") which promotes good conduct in relation to processing personal information.
These Principles are:
- Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject;
- Personal data shall be 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 or statistical purposes shall, in accordance with Article 89(1) not be considered to be incompatible with the initial purposes. CPCA shall ensure that individuals whose data is processed will be informed as fully as possible about the purposes for which the information is being processed;
- Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- Personal data shall be 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;
- Personal Data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data 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, in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedom of the data subject;
- Personal data shall be 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. In particular, unauthorised staff and other individuals will be prevented from gaining access to personal information. Appropriate physical security will be in place with visitors being received and supervised at all times within CPCA's premises where information about individuals is stored;
- Personal data shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
CPCA shall ensure that the Information Commissioner's Office is informed of all its uses of personal information and will review and update those entries from time to time.
CPCA shall take such measures as may be necessary to ensure the proper training, supervision and instruction of all relevant employees in matters concerning data protection and to provide any necessary information.
CPCA shall consult with its employees periodically to ascertain what measures should be taken to increase awareness of data protection issues and to ensure that all necessary measures are in place to make this Policy effective.
Where reasonable and practicable personal data shared with any partner, associate or other organisation shall be the subject either of a protocol or confidentiality agreement which will define the context and limits of the data exchange.
The CPCA's Monitoring Officer shall have overall responsibility for data protection issues within the organisation.
The CPCA will keep this Policy under review taking account of changes in legislation, advice from the Information Commissioner's Office, decisions of the Courts, changes in technology, experience in practice and relevant guidance from other representatives.