Vision Link – Kings Lynn Talking Newspaper (KLTN), Charity 1048633

Data Protection Policy: Management of Subscribers Personal Data.
This document summarises the processes used in the Kings Lynn Talking Newspaper, Vision Link, to manage the personal data of subscribers, and to ensure compliance with the General Data Protection Regulation (GDPR. 2018).
  1.  The Kings Lynn Talking Newspaper, Vision Link, is a charity run by volunteers and with no official funding, to provide people who are visually impaired or blind with a free audio recording of the week’s news taken from the local paper (Lynn News).  After the weekly recording a USB memory stick containing the audio extract is sent to the home address of all subscribers
  2. The subscribers to KLTN mainly originate with referrals from the Norfolk and Norwich Association for the Blind (NNAB) who will obtain consent for their specific personal data, name and address only, to be shared with the KLTN for the legitimate use of providing a talking newspaper.
  3. Any subscriber who requests the KLTN not through the NNAB will be asked for consent to allow their specific data, name and address only, to be securely stored and processed to provide the service.
  4. Subscribers are informed of the specific personal data held by the KLTN, Vision Link and the key aspects of this data protection policy using the vehicle of the audio recording of the talking newspaper.
  5. This personal data is kept by the KLTN, Vision Link on a secure database (spreadsheet) and on address cards (used to attach to plastic envelopes for delivery of weekly recording).
  6. This personal data is only available to the KLTN, Vision Link members and is not shared with any other organisations. There are no circumstances where the subscribers’ data will be disclosed outside of Vision Link.
  7. The spreadsheet database is maintained and kept securely on a personal computer by the Secretary of Vision Link, who acts as the Data Controller and Processor.
  8. An up to date printout of this spreadsheet is provided by the Secretary and is kept securely in the Recording Studio. This spreadsheet is replaced with an updated version on a regular basis, and the previous paper version disposed of in a secure manner.
  9. The address cards, typically 4 for each subscriber, are kept securely in the Recording Studio.
  10. The paper printout of subscribers is reviewed on a regular basis, typically every 3 months, to ensure the accuracy and completeness of the information. Any changes needed are notified to the secretary who then updates the subscribers’ spreadsheet database.
  11. As new referrals are received updates to the spreadsheet and new address cards are put in place by the Secretary.
  12. If NNAB or individual subscribers advise Vision Link that further editions of the Talking Newspaper are not required, then those subscribers will be removed from the spreadsheet database and their address cards disposed of in a secure manner.
Based on the above information that since: -
  • Vision Link only use a small sub-set of personal data already held by NNAB
  • and only Name and Address are legitimately kept as personal data by Vision Link
  • and processes are in place to maintain and keep this personal data secure
  • and personal data is not shared with anyone outside Vision Link
  • and processes are in place to inform subscribers of personal data held and to securely delete personal data when required
Then the view of the Kings Lynn Talking Newspaper, Vision link is that all reasonable steps are in place to ensure compliance with GDPR with respect to our subscribers.