Data Protection Policy

Moodle Users Association logo

Data Protection Policy

Moodle Users Association Inc

Last updated

21 May 2018

Definitions

Association

means the Moodle Users Association Inc, a not-for-profit association incorporated under the Government of Western Australia’s Associations Incorporation Act (2015).

GDPR

means the General Data Protection Regulation of the European Union.

Responsible Person

means the Secretary of the Association’s Committee of Management.

Register of Systems

means a register of all systems or contexts in which personal data is processed by the Association.

Act

means the Government of Western Australia’s Associations Incorporation Act (2015).


  1. Data protection principles

    The Association is committed to processing data in accordance with its responsibilities outlined in the Act and in compliance with the GDPR.

    Article 5 of the GDPR requires that personal data shall be:

    1. processed lawfully, fairly and in a transparent manner in relation to individuals;

    2. 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;

    3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

    4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, be erased or rectified without delay;

    5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is 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 GDPR in order to safeguard the rights and freedoms of individuals; and

    6. 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

    1. This policy applies to all personal data processed by the Association.

    2. The Responsible Person shall take responsibility for the Association’s ongoing compliance with this policy.

    3. This policy shall be reviewed at least annually.

  3. Lawful, fair and transparent processing

    1. The Moodle Users Association website is hosted by Moodle Pty Ltd and the processing of data is undertaken in line with their processes, as outlined in their privacy policy at: https://moodle.com/privacy-notice.

    2. The Register of Systems shall be reviewed at least annually.

    3. Individuals have the right to access their personal data and any such requests made to the Association shall be dealt with in a timely manner.

  4. Lawful purposes

    1. All data processed by the Association must be done in line with EU’s General Data Protection Regulation (GDPR), as outlined at: https://moodle.com/privacy-notice.

    2. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.

    3. 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 Association’s systems.

  5. Data minimisation

    1. The Association shall ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

    2. Personal data collected by the Moodle Users Association is available through the

      1. Membership profile

      2. User’s individual profile

    3. All personal data is able to be updated and viewed by the members and users on their relevant profile.

    4. Required data is limited to

      1. Membership information: First Name, Surname, Country, Email, Affiliation (in the case of organisation memberships)

      2. Billing information: Address

  6. Accuracy

    1. Members of the Association have full control over their personal membership and billing data and shall take reasonable steps to ensure personal data is accurate.

  7. Archiving / removal

    1. To ensure that personal data is kept for no longer than necessary, the Association shall put in place an archiving policy for each area in which personal data is processed and review this process annually.

    2. The archiving policy shall consider what data should/must be retained, for how long, and why.

    3. Past members retain read-only access to the Association activities, and personal data that has been collected.

    4. Where requested, personal data and access to the Association shall be deleted, except when required to be maintained for auditing purposes.

  8. Security

    1. The Association shall ensure that personal data is stored securely using Moodle Pty Ltd security systems and processes.

    2. The Association website is hosted and maintained on the servers of Moodle Pty Ltd by Moodle Pty Ltd staff .  

    3. The Association will process (collect, store and use) the information you provide in a secure manner compatible with the European Union General Data Protection Regulation. We will endeavour to keep your information accurate, secure and up to date, and not keep it for longer than is necessary.

    4. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.

    5. Personnel include voted members of the Committee of Management, in particular the Chairperson, Vice Chairperson, Treasurer, Secretary, and Webmaster; specific staff of Moodle Pty Ltd who support the website and billing procedures and are appointed by Moodle Pty Ltd management.

    6. Moodle Pty Ltd staff with access to the Association website and data are subject to the privacy and personal data security policy of the Association and Moodle Pty Ltd.

    7. When personal data is deleted this shall be done safely such that the data is irrecoverable, except where we are required to retain the information for auditing purposes.

    8. Appropriate back-up 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, the Association shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the Office of the Australian Information Commissioner.