Data Protection Policy
Women in Technology and Science is a voluntary, independent organisation advocating, connecting and acting for women to benefit society as full and vital participants in STEM.
The purpose of this document is to provide a clear policy statement regarding the Data Protection obligations of Women in Technology and Science. This includes obligations in dealing with personal data, in order to ensure that the organisation complies with the requirements of the relevant Irish legislation, namely the General Data protection Regulation (GDPR) 2018, the Irish Data Protection Act (1988), and the Irish Data Protection (Amendment) Act (2003).
Women in Technology and Science must comply with the data protection principles set out in the relevant legislation. This policy applies to all personal data collected, processed and stored by Women in Technology and Science in relation to its members and guests in the course of its activities. Women in Technology and Science makes no distinction between the rights of data subjects, all are treated equally under this policy.
The policy covers both personal and sensitive personal data held in relation to data subjects by Women in Technology and Science. The policy applies equally to personal data held in manual and automated form.
All personal and sensitive personal data will be treated with equal care by Women in Technology and Science. Both categories will be equally referred-to as personal data in this policy, unless specifically stated otherwise.
This policy should be read in conjunction with the associated GDPR document that outlines the Subject Access Request procedure, Data Retention and Destruction, the Data Retention Periods List and the Data Loss Notification procedure.
Women in Technology and Science WITS as a Data Controller
In the course of its daily organisational activities, Women in Technology and Science acquires, processes and stores personal data in relation to:
- Members of Women in Technology and Science
- Speakers and guests of Women in Technology and Science
- Third party service providers engaged by Women in Technology and Science
In accordance with the Irish data protection legislation, this data must be acquired and managed fairly. Not all WITS voluntary administrators will be expected to be experts in data protection legislation. However, Women in Technology and Science is committed to ensuring that its voluntary administrators have sufficient awareness of the legislation in order to be able to anticipate and identify a data protection issue, should one arise. In such circumstances, administrators must ensure that the Data Protection Officer is informed, and in order that appropriate corrective action is taken.
Due to the nature of the services provided by Women in Technology and Science, there is regular and active exchange of personal data between Women in Technology and Science and its Data Subjects. In addition, Women in Technology and Science exchanges personal data with Data Processors on the Data Subjects’ behalf.
This is consistent with Women in Technology and Science’s obligations under the terms of its contract with its Data Processors.
This policy provides the guidelines for this exchange of information, as well as the procedure to follow in the event that a Women in Technology and Science administrator is unsure whether such data can be disclosed.
In general terms, the administrator should consult with the Data Protection Officer to seek clarification.
Subject Access Requests
Any formal, written request by a data subject for a copy of their personal data (a Subject Access Request) will be referred, as soon as possible, to the Data Protection Officer, and will be processed as soon as possible.
It is intended that by complying with these guidelines, Women in Technology and Science will adhere to best practice regarding the applicable data protection legislation.
In the course of its role as Data Controller, Women in Technology and Science uses a number of data processors to process personal data on its behalf. These data processors include:
- MailChimp for newsletters and event information.
- PayPal for membership and events (where appropriate) payment
- Eventbrite for event bookings
- Google for WITS documentation and archive storage.
- WhatsApp for Executive and sub-committee communication
- Skype/Zoom for Executive meetings.
The Data Protection Principles
The following key principles are enshrined in the Irish legislation and are fundamental to the Women in Technology and Science’s Data Protection Policy.
In its capacity as Data Controller, Women in Technology and Science ensures that all data shall:
1. ....BE OBTAINED AND PROCESSED FAIRLY AND LAWFULLY.
For data to be obtained fairly, the data subject will, at the time the data are being collected, be made aware of:
- The identity of the Data Controller (Women in Technology and Science)
- The purpose(s) for which the data is being collected
- The person(s) to whom the data may be disclosed by the Data Controller
- Any other information that is necessary so that the processing may be fair.
Women in Technology and Science will meet this obligation in the following way.
- Where possible, the informed consent of the data subject will be sought before their data is processed;
- Where it is not possible to seek consent, Women in Technology and Science will ensure that collection of the data is justified under one of the other lawful processing conditions – legal obligation, contractual necessity, etc.;
- Where Women in Technology and Science intends to record activity on video, a Fair Processing Notice will be posted in full view;
- Processing of the personal data will be carried out only as part of Women in Technology and Science’s lawful activities, and Women in Technology and Science will safeguard the rights and freedoms of the data subject;
- The data subject’s data will not be disclosed to a third party other than to a party contracted to Women in Technology and Science and operating on its behalf.
2. .... BE OBTAINED ONLY FOR ONE OR MORE SPECIFIED, LEGITIMATE PURPOSES.
Women in Technology and Science will obtain data for purposes which are specific, lawful and clearly stated. A data subject will have the right to question the purpose(s) for which Women in Technology and Science holds their data, and Women in Technology and Science will be able to clearly state that purpose or purposes.
3. ..... NOT BE FURTHER PROCESSED IN A MANNER INCOMPATIBLE WITH THE SPECIFIED PURPOSE(S).
Any use of the data by Women in Technology and Science will be compatible with the purposes for which the data was acquired.
4. .... BE KEPT SAFE AND SECURE.
Women in Technology and Science will employ high standards of security in order to protect the personal data under its care. Appropriate security measures will be taken to protect against unauthorised access to, or alteration, destruction or disclosure of any personal data held by Women in Technology and Science in its capacity as Data Controller.
Access to and management of members’ records is limited to those administrators / Executive members who have appropriate authorisation and password access.
5. ... BE KEPT ACCURATE, COMPLETE AND UP-TO-DATE WHERE NECESSARY.
Women in Technology and Science will:
- ensure that administrative and IT validation processes are in place to conduct regular assessments of data accuracy;
- conduct periodic reviews and audits to ensure that relevant data is kept accurate and up-to-date. Women in Technology and Science conducts a review of sample data every year to ensure accuracy.
- conduct regular assessments in order to establish the need to keep certain personal data.
6. ... BE ADEQUATE, RELEVANT AND NOT EXCESSIVE IN RELATION TO THE PURPOSE(S) FOR WHICH THE DATA WERE COLLECTED AND PROCESSED.
Women in Technology and Science will ensure that the data it processes in relation to data subjects are relevant to the purposes for which those data are collected. Data which are not relevant to such processing will not be acquired or maintained.
7. ... NOT BE KEPT FOR LONGER THAN IS NECESSARY TO SATISFY THE SPECIFIED PURPOSE(S).
Women in Technology and Science has identified the data retention requirements for each type of data, in both a manual and automated format.
Once the respective retention period has elapsed, Women in Technology and Science undertakes to destroy, erase or otherwise put this data beyond use.
8. ... BE MANAGED AND STORED IN SUCH A MANNER THAT, IN THE EVENT A DATA SUBJECT SUBMITS A VALID SUBJECT ACCESS REQUEST SEEKING A COPY OF THEIR PERSONAL DATA, THIS DATA CAN BE READILY RETRIEVED AND PROVIDED TO THEM.
Women in Technology and Science has implemented a Subject Access Request procedure by which to manage such requests in an efficient and timely manner, within the timelines stipulated in the legislation.
Data Subject Access Requests
As part of the day-to-day operation of the organisation, Women in Technology and Science’s administrators engage in active and regular exchanges of information with data subjects. Where a formal request is submitted by a data subject in relation to the data held by Women in Technology and Science, such a request gives rise to access rights in favour of the Data Subject.
There are specific time-lines within which Women in Technology and Science must respond to the data subject, depending on the nature and extent of the request. These are outlined in the attached FAQ Guide to Subject Access Requests.
Women in Technology and Science’s administrators will ensure that, where necessary, such requests are forwarded to the Data Protection Officer in a timely manner, and they are processed as quickly and efficiently as possible, but within not more than 40 days from receipt of the request.
As a data controller, Women in Technology and Science ensures that any entity which processes personal data on its behalf (a data processor) does so in a manner compliant with the data protection legislation.
Failure of Women in Technology and Science’s administrators to process personal data in compliance with this policy will result in changes to the administration of Women in Technology and Science.
For the avoidance of doubt, and for consistency in terminology, the following definitions will apply within this Policy.
This includes both automated and manual data.
Automated data means data held on computer, or stored with the intention that it is processed on a computer.
Manual data means data that is processed as part of a relevant filing system, or which is stored with the intention that it forms part of a relevant filing system.
Information concerning or relating to an living person who is either identified or identifiable (such a person is referred to as a ‘data subject’), in conjunction with other data which is likely to come into the legitimate possession of the Data Controller. (If in doubt, Women in Technology and Science refers to the definition issued by the Data Protection Commission and updated from time to time.)
Sensitive Personal Data
A particular category of Personal Data, relating to: Racial or Ethnic Origin, Political Opinions, Religious, Ideological or Philosophical beliefs, Trade Union membership, Information relating to mental or physical health, information in relation to one’s sexual orientation, information in relation to commission of a crime and information relating to conviction for a criminal offence.
Women in Technology and Science does NOT collect or process sensitive personal data.
A person or entity who, either alone or with others, controls the content and use of Personal Data by determining the purposes and means by which that Personal Data is processed.
A living individual who is the subject of the Personal Data, i.e. to whom the data relates either directly or indirectly.
A person or entity who processes Personal Data on behalf of a Data Controller on the basis of a formal, written contract, but who is not an employee of the Data Controller, processing such Data in the course of his/her employment.
Data Protection Officer
A person appointed by Women in Technology and Science to monitor compliance with the appropriate Data Protection legislation, to deal with Subject Access Requests, and to respond to data protection queries from members, speakers and guests.
Relevant Filing System
Any set of information in relation to living individuals which is not processed by means of equipment operating automatically (computers), and that is structured, either by reference to individuals or by reference to criteria relating to individuals, in such a manner that specific information relating to an individual is readily retrievable.
- https://www.dataprotection.ie/ website of the Data Protection Commission