Personal data
If your TRA holds information about individuals either on a computer, or as part of a filing system then they hold personal data.
The Information Commissioner’s Office advises that the following two questions are asked to confirm if information is personal data:
- Can a living individual be identified from the data?
- Does the data relate to the identifiable living individual?
If the answer is yes to either of these questions, then it is considered personal data.
Personal data can include, but is not limited to:
- Name
- Address
- Telephone number
- Email address
- Date of birth
- Ethnicity
- Sexual orientation
- Medical conditions
- Household earnings
- Views on a specific subject that can be identified back to an individual – just because you do not know the name of an individual does not mean you cannot identify that individual.
When collecting personal data TRAs need to think about the following:
- What information are they collecting.
- Why they are collecting this information.
Only information which is going to be used for a specific and stated purpose should be collected. Those giving the information should know what the specific purpose is before they give the information, and this should not be changed after the information has been given.
How they are going to collect the information
TRAs should set out if this will be via survey, by email, in a notebook, in a table etc…
How long they are going to hold the information
Personal information should only be held for as long as it is necessary, based on the specific purpose that it was collected for and the type of information that it is.
What sort of personal data might TRAs be collecting?
This list is not exhaustive. There may be other activities you need to consider.
Surveys, Petitions, Spreadsheets, Gardening club sign-up sheets etc
We actively encourage TRAs to consult with the residents they represent to find out if there is support for activities and community improvement schemes. We recommend that TRAs only collect general information to show support for projects. This could be done by a show of hands at a TRA meeting, or by collecting signatures in support of a project or idea. Any spreadsheets should be password protected and only information for a specifically stated purpose should be kept.
Making funding bids
Funding bids will often need to be signed by the active committee members or fundraisers. They will also need to supply contact details. It is advisable for TRAs to keep a record of their funding bids and return correspondence either in hard copy of electronic form.
Sending a group email
When sending a group email, you should make sure you have permission to share other individuals’ email addresses with other people. You can either ask for this for one specific purpose or ask for advance agreement for sharing their email address. If you are sending emails to people who haven’t given their permission, you should blind copy (BCC) them into the email, so their email address is not visible.
When we communicate with TRAs we will use a generic email address where possible (e.g. TRAname@gmail.com). We will only write to and share resident email addresses where permission has been given. If a resident is a member of another group that we are running, we will use their agreed personal email address to keep in touch with them.
Recording meeting minutes
Sometimes at TRA meetings there may be conversations about a resident, or a property and any actions being taken. Any details that could identify an individual should not be recorded in the minutes because it is not possible to control the circulation of the meeting minutes. Comments should also not be attributed to an individual and should be noted as “the group discussed…”
Using a phone number on a poster
TRAs who manage halls and hire them out often advertise on their notice boards, or on websites. Committee members should think about which phone numbers are being advertised and seek agreement for any committee members’ personal numbers that are listed. One way to address this is for the committee to purchase mobile phones specifically for this purpose.
Registering the TRA
TRAs must register with H&F on an annual basis, so that we are getting in touch with the right committee members. We use these contact details to consult with TRAs on things that are planned in their area. We also inform TRAs of up-and-coming meetings, events, and funding opportunities. Residents who are committee members give us their contact details on the understanding that we will contact them for this purpose.
Hall/room hirers information
Hall hirers will need to provide their contact details and potentially bank account details (on cheques). This information should be stored securely in a safe place.
The secure disposal of any personal data should also be undertaken with care. A shredder or confidential waste service should be used at all times.