Data Protection Policy
The Lion of Judah Ministries, Inc.
Many Americans have never heard of the “GDRP.” But if you are part of an organization which is involved in internet communications which may extend to Europe (LOJM has friends and supporters who live in Europe, too!), then you probably have, at least, heard of it. It is a law designed to protect the personal information of internet users. It applies to charities and not-for-profits. So we need to be in compliance with it.
You probably don’t want to read all of it, and in the case of The Lion of Judah Ministries, the reality is we have very little of your personal information to begin with!
So in plain language, here is the essence of what this policy says:
Any of the personal information LOJM has about you must be information you intentionally and knowingly provide to us (no sneaky collection of your information allowed!)
We promise to use that information only with your explicit permission and only for the purposes you provide it. In addition, any time you want us to delete part or all of it, we will do that as soon as you tell us.
We will be completely open and transparent with you about what information we have and how we use it.
Now…how does that apply to Lion of Judah Ministries, specifically?
1. Unless you make financial donations, the only information we have about you is what you give us to communicate with you: in most cases your name and email address, perhaps your postal address and telephone number. We promise to use that only to communicate with you about the school and ministry. We promise never to share that with anyone else, for any purpose at all.
2. If you are a donor we will have some very limited financial information related to your contributions. We have the amounts you have contributed, of course. But in terms of your personal financial information, what we have is limited to either,
a) whatever is printed on your personal check, if you contribute via check;
b) if you contribute online via PayPal or ReachApp, you contribute through a third party processing system (PayPal has its own, and ReachApp uses Stripe.com). Those processing systems have access to your payment information so they can process your payment and then forward the contribution to us. They have their own privacy policies and they do not share that information with us at LOJM.
Regarding the limited personal information of yours we do have: We promise to use it only for the purposes for which you provided it to us. We promise not to share any of it with any one, for any reason, at any time. We promise to keep your information as safe and secure as possible. We promise if we have any reason to think someone outside our organization has gotten access to information you have entrusted to us, we will tell you right away. We promise to be open and transparent with you. We promise that if you want us to delete your information, we will do that right away.
So, that’s basically what all the formal language in the policy below adds up to.
Please feel free to contact us with any questions!
The Lion of Judah Ministries
Below is the formal policy as required by the GDPR
Updated: September 15, 2021
|Charity||Means The Lion of Judah Ministries, Inc.|
|GDPR||means the General Data Protection Regulation.|
|Responsible Person||is Hartford Inlow, Board Secretary|
|Register of Systems||means a register ( a list) of all systems or contexts in which personal data is processed by The Lion of Judah Ministries|
1. Data protection principles
The Charity is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- 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, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- 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;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are 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, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.”
2. General provisions
- This policy applies to all personal data processed by the Charity.
- The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
3. Lawful, fair and transparent processing
- To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.
- The Register of Systems shall be reviewed at least annually.
- Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner.
4. Lawful purposes
- All data processed by the charity must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
- The Charity shall note the appropriate lawful basis in the Register of Systems.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Charity’s systems.
5. Data minimization
- The Charity shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- The Charity shall take reasonable steps to ensure personal data is accurate.
- Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
7. Archiving / removal
- To ensure that personal data is kept for no longer than necessary, the Charity shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
- The archiving policy shall consider what data should/must be retained, for how long, and why.
- The Charity shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
- Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorized sharing of information.
- When personal data is deleted this should be done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions shall be in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, the Charity shall promptly assess the risk to people’s rights and freedoms and take appropriate action.
END OF POLICY