Definitions and Responsibilities
| Organisation | Nottingham Forest Supporters Trust (NFST), the trading name of 1865 Supporters Society Limited. |
|---|---|
| UK GDPR and DPA | The UK General Data Protection Regulation and the Data Protection Act 2018. |
| Responsible Persons | James Bogue and Vicki Connell (Communications and Membership Secretaries) act as Data Controller's representatives and Data Protection Officer. |
| Register of Systems | A register of all systems or contexts in which personal data is processed by NFST. |
| Areas covered by this Policy | Memberships and Board members. |
| Overall accountability | Asif Naidu, Chair, on behalf of the Board. |
1. Data Protection Principles
NFST is committed to processing data in accordance with its responsibilities under the UK GDPR and the Data Protection Act 2018. NFST's prime data processing activity is membership. Article 5 of the UK 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 organisational measures required by the UK 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 unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
2. General Provisions
- This Policy applies to all personal data processed by NFST.
- The Communications and Membership Secretaries act as Data Protection Officer and take responsibility for NFST's ongoing compliance with this Policy.
- This Policy shall be reviewed at least annually.
- NFST is not required to register with the Information Commissioner's Office (ICO) because of its not-for-profit status. NFST remains subject to the UK GDPR and to the ICO's oversight.
3. Lawful, Fair and Transparent Processing
- To ensure its processing of data is lawful, fair and transparent, NFST shall maintain a Register of Systems. The systems currently in use are, but are not limited to, Coreflow AI, WhatsApp, Microsoft 365, PayPal and Stripe. NFST may from time to time share data with Mi-Voice (mi-voice.com) in respect of the election process for Board members.
- The Register of Systems shall be reviewed at least annually. Between reviews, systems may be changed where deemed appropriate; if a change is made, the Register of Systems will be updated immediately.
- Individuals have the right to access their personal data, and any such request made to NFST shall be dealt with in a timely manner and within the statutory one month.
4. Lawful Purposes
- All data processed by NFST must be processed on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
- NFST 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 shall be clearly available, and systems shall be in place to ensure such revocation is reflected accurately in NFST's systems.
5. Data Minimisation
- NFST shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
6. Accuracy
- NFST 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, at least on an annual basis.
7. Retention and Removal
- To ensure that personal data is kept for no longer than necessary, NFST shall put in place a retention review for each area in which personal data is processed, and shall review this process at least annually.
8. Security
- NFST 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 shall be in place to avoid unauthorised sharing of information. Current access is given to the Communications and Membership Secretaries; any further access must be authorised by the Chair.
- When personal data is deleted this shall be done safely, such that the data is irrecoverable.
- Appropriate backup and disaster recovery solutions shall be in place.
9. Breach
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, NFST shall promptly assess the risk to people's rights and freedoms and, if appropriate, report the breach to the ICO within 72 hours (more information is available on the ICO website).
10. Training
All Board members and volunteers handling personal data are required to update their knowledge of data protection principles through annual training, which will be recorded through Board meetings. Any further changes will be communicated to all relevant personnel by the Data Protection Officer.
Legislation Links
- Information Commissioner's Office (ico.org.uk)
- Data Protection Act 2018 (legislation.gov.uk)
- ICO data protection fee self-assessment
Approved by the Board of 1865 Supporters Society Limited, November 2026. Next review due November 2027.