? Cumberwell Park Golf Club - 36 Holes Wiltshire Golf Cumberwell Park Golf Club - 36 Holes Wiltshire
Cumberwell park Golf Club Data Protection Policy Cumberwell Park takes its responsibilities with regard to the management of the requirements of the Data Protection Act 1998 very seriously. This document provides the policy framework through which effective management of Data Protection matters can be achieved. Cumberwell Park be here on be referred to as ‘CP’.

1. Scope of the Policy

The purpose of this policy is to ensure that the CP’s staff comply with the provisions of the Data Protection Act 1998 when processing personal data. Any serious infringement of the Act will be treated seriously by CP and may be considered under disciplinary procedures. CP expects its entire staff to follow the ethical behaviours set out in the Nolan Principles. Those are: selflessness, integrity, objectivity, accountability, openness, honesty and leadership. These Principles underlie the CP’s Ethical Framework and are incorporated into this policy.

This policy applies regardless of where the data is held, ie if it is held on personally-owned equipment or outside the CP’s property.

CP is required to adhere to the eight principles of data protection as laid down by the Act. In accordance with those principles personal data shall be:
1. Processed fairly and lawfully
2. Processed for specified purposes only
3. Adequate, relevant and not excessive
4. Accurate and up to date
5. Not kept longer than necessary
6. Processed in accordance with data subjects’ rights
7. Processed and held securely
8. Not transferred outside the countries of the European Economic Area without adequate protection.

2. Responsibilities

[a] CP responsibilities
As the Data Controller CP is responsible for establishing policies and procedures in order to comply with the requirements of the Data Protection Act 1998.

[b] Data Protection Officer responsibilities
CP’s Data Protection officer holds responsibility for:
• CP’s Data Protection. Anyone who is, or intends, processing personal data for purposes not included in the existing procedures should seek advice from the CP’s Data Protection officer;
• drawing up guidance, giving advice and promoting compliance with this policy in such a way as to ensure the easy, appropriate and timely retrieval of information;
• the appropriate compliance with subject access rights and ensuring that data is released in accordance with subject access legislation under the Data Protection Act 1998;
• ensuring that any data protection breaches are resolved, cataloged and reported appropriately in a swift manner and in line with guidance from the Information Commissioner’s Office;
• investigating and responding to complaints regarding data protection including requests to cease processing personal data.

[c] Staff responsibilities
Staff members who process personal data about guests, members or any other individual must comply with the requirements of this policy.
Staff members must ensure that:
• all personal data is kept securely;
• no personal data is disclosed either verbally or in writing, accidentally or otherwise, to any unauthorised third party; • personal data is kept in accordance with the CP’s retention schedule;
• any queries regarding data protection, including subject access requests and complaints, are promptly directed to the Data Protection Officer;
• any data protection breaches are swiftly brought to the attention of the Data Protection Officer and that they support the Data Protection Officer in resolving breaches;
• where there is uncertainty around a Data Protection matter advice is sought from the Data Protection Officer. Staff who are unsure about who are the authorized third parties to whom they can legitimately disclose personal data should seek advice from the Data Protection Officer.

[d] Third-Party Data Processors
Where external companies are used to process personal data on behalf of CP, responsibility for the security and appropriate use of that data remains with the CP.
Where a third-party data processor is used:
• a data processor must be chosen which provides sufficient guarantees about its security measures to protect the processing of personal data;
• reasonable steps must be taken that such security measures are in place;
• a written contract establishing what personal data will be processed and for what purpose must be set out;
• a data processing agreement, available from the Data Protection Officer, must be signed by both parties.
For further guidance about the use of third-party data processors please contact the Data Protection Officer.

3. Subject Access Requests
CP is required to permit individuals to access their own personal data held by CP via a subject access request. Any individual wishing to exercise this right should do so in writing to the Data Protection Officer.
CP aims to comply with requests for access to personal information as quickly as possible, but will ensure that it is provided within the 40 calendar day limit set out in the Data Protection Act 1998.
Individuals will not be entitled to access information to which any of the exemptions in the Act applies. However, only those specific pieces of information to which the exemption applies will be withheld and determining the application of exemptions will be made by the Data Protection Officer.

4. Data Protection breaches
Where a Data Protection breach occurs, or is suspected, it should reported immediately in accordance with the Data Security Breach Incident Management Policy which states:
Confirmed or suspected data security breaches should be reported promptly to the Ali James – Golf Manager as the primary point of contact on 01225 863322, email: admin@cumberwellpark.com. The report should include full and accurate details of the incident including who is reporting the incident and what classification of data is involved.

5. Contact
Queries regarding this policy or the Data Protection Act at large should be directed to the Data Protection Officer at admin@cumberwellpark.com

The two three years' projects, named "guarding the replica watches uk earth from this moment", work together with local environmental replica watches activists to replica uk watches promote important natural heritage and protect fake watches local economic activities.