Data Protection Policy and Procedures


We are committed to a policy of protecting the rights and privacy of individuals. We need to collect and use certain types of data in order to carry on our work of managing St Margaret’s Hall (SMH), a registered charity. By law this personal information must be collected and handled securely and any breaches must be reported and may result in fines.

All of the members of the SMH Managing Committee are Charity Trustees and are referred to throughout this policy as Trustees.

What is ‘personal information’?

Personal Information is defined as information about living individuals that enables them to be identified – e.g. names, addresses, telephone numbers and email addresses. It does not apply to information about organisations, companies and agencies but applies to named persons.

The Law

The Data Protection Act 1998 (DPA) and General Data Protection Regulations (GDPR) 2018 govern the use of information about people (personal data). Personal data can be held on computers, laptops and mobile devices, or in a manual file, and includes email, minutes of meetings, and photographs.

The charity will remain the data controller for the information held. SMH Trustees and staff are personally responsible for processing and using personal information in accordance with the Data Protection Act and GDPR. Trustees and staff who have access to personal information will therefore be expected to read and comply with this policy.

Purpose of this policy

The purpose of this policy is to set out publicly the SMH commitment and procedures for protecting personal data. (It will be posted on the SMH website and copies will be available on request from SMH).

Trustees regard the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal with. We recognise the risks to individuals of identity theft and financial loss if personal data is lost or stolen.

The Data Protection Act

This contains 8 principles for processing personal data with which we must comply.

Personal data:

  1. Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met,
  2. Shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes,
  3. Shall be adequate, relevant and not excessive in relation to those purpose(s).
  4. Shall be accurate and, where necessary, kept up to date,
  5. Shall not be kept for longer than is necessary,
  6. Shall be processed in accordance with the rights of data subjects under the Act,
  7. Shall be kept secure by the Data Controller (The SMH Trustees) which takes appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal information,
  8. Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal information.

Applying the Data Protection Act within SMH

We will let people know why we are collecting their data, which is for the purpose of managing the hall, its hirings and finances. It is our responsibility to ensure the data is only used for this purpose. Access to personal information will be limited to Trustees and staff.

Correcting data

Individuals have a right to make a Subject Access Request (SAR) to find out whether the charity holds their personal data, where, what it is used for and to have data corrected if it is wrong, to prevent use which is causing them damage or distress, or to stop marketing information being sent to them.

Any SAR must be dealt with within 30 days. Steps must first be taken to confirm the identity of the individual before providing information, requiring both photo identification e.g. passport and confirmation of address e.g. recent utility bill, bank or credit card statement.

Individuals can contact the SMH via its published email address (currently or by writing to The Secretary, St Margaret’s Hall Management Committee, St Margaret's Hall, St Margarets's at Cliffe ,Reach Road, Dover, Kent, CT15 6AP

Our Responsibilities

SMH (The Trustees) is the Data Controller under the Act, and is legally responsible for complying with Act, which means that it determines what purposes personal information held will be used for.

The management committee will take into account legal requirements and ensure that it is properly implemented, and will through appropriate management, strict application of criteria and controls:

  • Collection and use information fairly.
  • Specify the purposes for which information is used.
  • Collect and process appropriate information, and only to the extent that it is needed to fulfil its operational needs or to comply with any legal requirements
  • Ensure the quality of information used.
  • Ensure the rights of people about whom information is held, can be exercised under the Act.

These include:

  1. The right to be informed that processing is undertaken.
  2. The right of access to one’s personal information.
  3. The right to prevent processing in certain circumstances, and
  4. The right to correct, rectify, block or erase information which is regarded as wrong information.
  • Take appropriate technical and organisational security measures to safeguard personal information,
  • Ensure that personal information is not transferred abroad without suitable safeguards,
  • Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information,
  • Set out clear procedures for responding to requests for information. All Trustees and staff are aware that a breach of the rules and procedures identified in this policy may lead to action being taken against them.

Procedures for Handling Data & Data Security

SMH has a duty to ensure that appropriate technical and organisational measures and training are taken to prevent:

  • SMH has a duty to ensure that appropriate technical and organisational measures and training are taken to prevent:
  • Unauthorised or unlawful processing of personal data
  • Accidental loss of personal data

All Trustees and staff must therefore ensure that personal data is dealt with properly no matter how it is collected, recorded or used. This applies whether or not the information is held on paper, in a computer or recorded by some other means e.g. tablet or mobile phone.

Personal data relates to data of living individuals who can be identified from that data and use of that data could cause an individual damage or distress. This does not mean that mentioning someone’s name in a document comprises personal data; however, combining various data elements such as a person’s name and salary or religious beliefs etc. would be classed as personal data, and falls within the scope of the DPA. It is therefore important that all staff consider any information (which is not otherwise in the public domain) that can be used to identify an individual as personal data and observe the guidance given below.

Privacy Notice and Consent Policy

We are advised that if SMH is only processing data for an obvious purpose such as managing the hall’s bookings and finances it does not need to give out privacy notices. However, for the avoidance of doubt we are also advised to display one on our website and have paper copies available on request.

The privacy notice will read:

‘St Margaret’s Hall uses personal data for the purposes of managing the hall, its bookings and finances, running and marketing events at the hall, staff employment and its fundraising activities. Data may be retained for up to 7 years for accounts purposes and for longer where required by the hall’s insurers. If you would like to find out more about how we use your personal data or want to see a copy of information about you that we hold, please contact the Hall Secretary’.

Consent forms would only be required if we were using personal information for purposes other than for managing the hall (e.g. giving or selling personal information to a third party) So no consent forms are required at this time.

Film Club

The monthly ‘Bring a Cushion Club’ is run for the benefit of the hall and the village of St Margaret’s by members of the Management committee. There is no membership fee or charge, although donations are welcome.

A separate mailing list is maintained on a personal computer by a member of the managing committee to let those who have asked to be informed about which films are due to be shown. This information includes only names and email addresses.

This list will:

  • Only be kept on a password protected PC
  • It will only be used for promoting the film club
  • It will not be shared with other individuals or organisations
Data Privacy Notice

The ‘Bring a Cushion Film Club’ (operated by the Management Committee of St Margaret’s Hall) wishes to fully comply with the 2018 General Data Protection Regulation (GDPR). In order to promote the club we hold your name and email address on a list so that we can keep you informed about the activities of the club. We will never share this information with others or use it for purposes unconnected with the activities of the film club. If you wish to have your name removed from our list at any time please contact us as soon as possible. A full copy of the Data Protection Policy for St Margaret’s Hall is available on the hall website at (or by request from the Hall Secretary.)

The Hall Website

SMH has a website to promote its activities, Currently the website does not collect any names and addresses and the only personal data displayed is that of contact names and information about club organisers and some photos of their activities who have supplied this for the normal purposes of their clubs. We do not use cookies.

Google Analytics is used to collect data to monitor the website usage and improve its functionality. Google Business provides website stats to the Village Hall committee on a monthly basis. The data collected is also used to improve the visitors experience by identifying trends and modifying the site to respond to these trends. The data is processed by Google who are listed as GDPR compliant.

Data Subject Access Requests:

We may occasionally need to share data with other agencies such as the local authority, funding bodies and other voluntary agencies in circumstances which are not in furtherance of the management of the charity. The circumstances where the law allows the charity to disclose data (including sensitive data) without the data subject’s consent are:

  • Carrying out a legal duty or as authorised by the Secretary of State Protecting vital interests of a Data Subject or other person e.g. child protection
  • The Data Subject has already made the information public
  • The Data Subject has already made the information public
  • Monitoring for equal opportunities purposes – i.e. race, disability or religion

Risk Management:

The consequences of breaching Data Protection can cause harm or distress to service users if their information is released to inappropriate people, or they could be denied a service to which they are entitled. Trustees and staff should be aware that they can be personally liable if they use customers’ personal data inappropriately. This policy is designed to minimise the risks and to ensure that the reputation of the charity is not damaged through inappropriate or unauthorised access and sharing.

Reporting a data breach

All organisations are required to report certain types of data breach to the ICO and in some cases to the individuals affected. A report to Hall Chairman should be made in the first instance. Any report to the ICO must be made within 72 hours (3 days) of becoming aware that an incident is reportable. Ring the ICO's helpline 0303 123 1113 for clarification if you are unsure whether something represents a significant breach.

A personal data breach means a breach of security leading to the destruction, loss, alteration, unauthorised disclosure of, or access to, personal data. You only have to notify the ICO where it is likely to result in a risk to individuals: For example, damage to reputation, financial loss, loss of confidentiality. If a data breach occurs, it is important to check whether anything could be done to avoid it happening again.

The implication for village halls is that all Trustees, employees and volunteers need to be aware that it is essential that any PC, laptop, mobile, tablet, CD or memory stick used for village hall purposes is password protected and that if any of these items are stolen or hacked, and risk to individuals results, the breach is reported. The same applies to paper files.

This policy last updated November 2018.



Fully equipped Kitchen

• Dimensions 6.6m x 3.8m (22' x 12.5')
• Two large catering ovens
• Dishwasher
• Double sinks
• Crockery and cutlery provided

Fully Licenced Bar

On Site Bar

Fully equipped & staffed bar

• Accessible from both ground floor venues
• Large range of alcoholic and soft drinks at good prices
• Trained staff
• Happy to provide additional named wines and beers if required

Equipment Available For Use By Hirers


Equipment for use by hirers

• Microphones and sound system in Main Hall
• Projector and screen in Main Hall
• Projector and screen in Channel Room
• Fairy lights in Main Hall
• New Lighting System.
Our recently installed DMX LED PAR Cans will add a Wow factor to your event. These discreet light fittings throw pools of changing coloured light onto the main dance floor. They can work independently via our controller, or you can link to your own system. Our technical team will be pleased to advise and assist
Please ask for details