Macalla Farm Data Protection Policy

Macalla Farm Ltd is committed to protecting the rights and freedoms of data subjects and safely and securely processing data in accordance with all of our legal obligations under the General Data Protection Regulation (GDPR).
We hold personal data about our guests, volunteers, suppliers and other individuals for a variety of business purposes. We do not share data collected from guests with anyone, but note that booking forms may be checked through an automated spam detection service.

1. Data protection principles

Macalla farm Ltd is committed to collecting, storing and processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:

a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving or statistical purposes shall not be considered to be incompatible with the initial purposes;
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step will be taken to ensure that personal data that are inaccurate or no longer needed, having regard to the purposes for which they were initially collected, are erased or rectified without delay;
e. 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 or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
f. 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

a. This policy applies to all personal data processed by Macalla Farm Ltd.
b. The Company directors take responsibility for Macalla Farm’s ongoing compliance with this policy.
c. This policy shall be reviewed at least annually.

3. Lawful, fair and transparent processing

a. To ensure its processing of data is lawful, fair and transparent, Macalla Farm shall maintain a Register of Systems.
b. The Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and ask for it to be updated. Any such requests made to Macalla farm shall be dealt with in a timely manner.
d. Individuals can request at any time that all their personal data held by Macalla Farm be deleted from all our system.  However, if an individual making such a request has a booking pending,  this request will be deemed to amount to a booking cancellation.

4. Lawful purposes

a. All data collecting and processing by Macalla Farm must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests or legitimate interests.
b. Macalla Farm shall note the appropriate lawful basis in the Register of Systems.
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent will be kept with the personal data.
d. Our email newsletter is sent to individuals based on their consent, and the option for individuals to revoke their consent is clearly available. Such revocation takes effect immediately.

5. Data minimisation

a. Macalla Farm shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
b. Personal data is collected from our guests through online booking forms and stored on our secure web server for up to a year after the date of the course. This data is only accessible to our website administrators.
c. Data collected via email from guests, suppliers, employees and volunteers may also be stored on personal computers.
You can request that all your personal data is deleted from our system immediately after your stay, but note that if you do so, you won’t be able to apply for the returnee discount on any further courses. This does not include any data we are obliged to keep for administrative, legal, or security purposes, which we will keep for as long as necessary.

6. Accuracy

a. Macalla Farm takes reasonable steps to ensure personal data is accurate.
b. Where necessary for the lawful basis on which data is processed, steps are put in place to ensure that personal data is deleted or kept up to date.

7. Archiving / removal

a. To ensure that personal data is kept for no longer than necessary, Macalla Farm has put in place an archiving policy for each area in which personal data is processed and review this process annually.
b. The archiving policy considers what data should/must be retained, for how long, and why.

8. Security

a. Macalla Farm ensures that personal data is stored securely using modern software that is kept-up-to-date.
b. Access to personal data is limited to personnel who need access and appropriate security is in place to avoid unauthorised sharing of information.
c. When personal data is deleted this is  done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions are 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, Macalla Farm shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the authorities.

10. Register of Systems

a. Macalla Farm secure web server stores data from guests collected through our online booking system. This data is necessary for us to communicate effectively with them prior to their stay, and to ensure that their stay is safe and enjoyable. It is protected by up to date security software and strong passwords, and is  only accessible to our website administrators.
b. Macalla Farm’s directors’ computers may store data from guests, as well as from suppliers, employees and volunteers which are necessary for the day to day running of the business, as well as for commercial and statistical purposes.
All systems are adequately password protected. This is reviewed yearly or when necessary.

11. Archiving policy

a. Personal data from guests may be stored for up to a year on Macalla Farm web server. Guests can however request that all their data be deleted immediately after the end of their stay at the farm.
b. Personal data from guests, suppliers, employees and volunteers may be stored on Macalla Farm’s or Macalla Farm’s employees computers (excluding its web server) for as long as necessary. This is reviewed yearly or when necessary.