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DPO as a Service For Charities

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DPO for all types of charities and not-for-profit organisations

Data Privacy Services provides skilled and experienced data protection professionals for all types of charitable organisations.

We currently provide discounted services for numerous charities.

Note – we can provide discounts for charities, see details below.  Up to 30% off the stated monthly subscription.

Role of a DPO in the charity sector

A DPO ensures that you meet a specified legal requirement and acts as the point of contact for all data protection requirements.

Reviews and Monitors Compliance

A DPO’s role includes the review and on-going monitoring of compliance with the data protection legislation.

This typically means that the DPO will complete an annual audit of the charities compliance and develop and maintain a Privacy by Design Plan.

Manages Privacy by Design

As part of the compliance monitoring activities the DPO will review how Privacy by Design is implemented into the charities operational processes and procedures.

This is a specific requirement under Article 25 and must be in place to be compliant.

Manages Data Breaches

The DPO should act as the central point of contact for any data breach that occurs within the charity (assuming this involves personal data).

The DPO should have the experience needed to follow the legal and best practice methodology for managing incidents. They will provide advice and guidance and ensure that the correct steps are taken to minimise risk.

Note – they will also be the point of contact with the associated Information Regulator (e.g. the UK’s Information Commissioners Office).

Record of the Processing

The DPO is required to keep an up-to-date record of the processing (ROPA) of the personal data that the charity processes as a Data Controller and Data Processor.

The ROPA is a legal requirement under Article 30.

Management of DSARs

Data Subject Access Requests (DSARs) are commonly requested by individuals (i.e. the Data Subject) when exercising their rights under data protection legislation.

The DPO must ensure that the requests are appropriately managed in accordance with the legislative requirements.

Provides Training

A DPO should provide training to all charity workers and volunteers on matters of both data protection and information security awareness.

There are specific legal requirements to train staff (under both Articles 5 and 32) so the DPO must ensure that this is in place and is fit for purpose.

UK and EU Representation

Article 27 of the EU and UK GDPR requires that organisations provide a geographically located representative for citizens of the EU and UK.

UK Representative

This applies when a charity is based in one region (i.e.the EU) and they process UK citizens data.

In this case, the UK representative must have an office in the UK.

EU Representative

This applies when a charity is based UK and they process EU citizens data.

In this case, the EU representative must have an office in the EU.

So, in the case of charities, this applies if you have workers, donors or beneficiaries that reside for at least part of the year inside the EU.

Note – We have offices in both the UK and EU and can support this requirement.

Processing of personal data within a charity setting

There are some specific requirements to consider when processing personal data within a charity setting.

Donors and Marketing

All charities have significant challenges in securing donors and sufficient revenue for their charitable activities.

Marketing is a major part of this challenge and data protection is also a considerable factor in the overall process.

We are specialists in reviewing legal basis for processing of donor details and also working with charities to ensure that they follow the regulations of the PECR and obviously the UK and EU GDPR.

Software Requirements

Charities have many different software requirements, all of which need to conform with data protection.

Systems such as:

  • Donor management tools (e.g. CRM tools)
  • Marketing tools (e.g. mass email marketing solutions)
  • Beneficiary management solutions

The use of the above software will need to have the appropriate risk assessments and compliance measures in place.

Management of Sensitive Personal Data

Many charities have to process sensitive (special categories) data about their beneficiaries.

Note – this means that some charities have a legal requirement to appoint a DPO.

Typically, this is done under the basic requirements of providing the service but the correct legal basis for processing and other requirements need to be followed. 

Data Privacy Services are experienced in managing complex charitable environments where there is significant sensitive information that is shared between staff, volunteers, local authorities, healthcare providers and law enforcement.

Also, Data Privacy Impact Assessments (DPIA) are required under the legislation for all of this category of processing.

Article 8 - Children's Data Processing

In terms of data protection, children under the age of 13 have to be treated differently than those aged 13 and over.

This causes significant complexity for some charities and the way that the legal basis for the processing is obtained must be in compliance with the legislation.

There are crucial rules to follow with regards to how charities communicate and manage the legal the basis for processing in areas such as:

  • Donor Newsletters /  SMS
  • Media usage (e.g. images, CCTV etc)
  • Social media
  • Charity / Beneficiary communications
  • Charity / Donor communications
  • Charity / Trustee communications
  • General photography involving any data subjects
Complex Data Subject Requirements

Charities process personal data of a wide variety of individuals also known data subjects.

These include:

  • Prospective Donors
  • Donors
  • Beneficiaries
  • Employees
  • Volunteers
  • Trustees
  • Local Authority Workers
  • Local Healthcare Providers
  • Children under the age of 13
Policies and Procedures

There are numerous policies and procedures that must be in place in order for the charity to be compliant.

Also, these documents must be broadly communicated, understood and implemented to demonstrate compliance.

Information and Cyber Security

All charities must be doing everything they possibly can to secure the integrity, confidentiality and availability of personal data.

This requirement is complex and must be fully assessed as to what is required for compliance.

Note – this also includes due-diligence on your supplier network.

Fundraising Essentials

There are some useful guidelines on the basics of data protection and how organisations need to comply with this during their fundraising activities.

Refer to: Institute of Fundraising

Are you concerned about your information security?

Current Incentives

We are offering discounts of 10% for 6 month contracts paid up front of 15% for 12 month contracts paid up front

DPO Service Levels

No fixed term contract, discount available on stated prices.

Benefits of engaging an outsourced DPO

We are an affordable and cost-effective option

There are many reasons to outsource the DPO function within your charity, e.g.

Avoiding a conflict of interest – there are legal requirements regarding the DPO and the potential for conflict of interest.  That said, typically a Trustee or Manager or  cannot perform the function of a DPO.  So engaging a DPO from Data Privacy Services removes this as an issue.

It’s rarely a full-time role – the DPO role isn’t often required to be a full time role within most charities.  Outsourcing to us enables you to engage a part-time DPO on a flexible working arrangement.

The DPO has to be qualified and experienced – this is a challenging requirement for most charities to fulfill.  Employing an experienced certified DPO will put a significant additional cost to your operating overheads.  Engaging one of our DPO resources is far more affordable and cost-effective.

You can call on additional resources – Data Privacy Services has a number of DPOs and also additional professional consultants who specialise in other areas such as information and cyber security.

We also provide you with additional services – these include training courses, online portal and Dark Web monitoring services.  You will also be able to access some of our information and cyber security solutions to ensure that you can protect your personal data.

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