Last updated 18th November 2025
Definitions:
- Committee means the committee arranging the Islip Big Bike Ride (BBR). A for-charity event on
behalf of The Friends of Dr South’s Primary School, and St Nicholas Church. - GDPR means the General Data Protection Regulation.
- Register of Systems means a register of all systems or contexts in which personal data is processed by the Committee.
- Responsible Person means Dan Levy (Chair of the Committee).
1. Data protection principles
The Committee is committed to 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 purposes in the
public interest, scientific or historical research purposes 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 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
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 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
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 the Committee
b. The Responsible Person shall take responsibility for the Committee’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, the Committee shall maintain a
Register of Systems (See Appendix 3)
b. The Register of Systems shall be reviewed at least annually
c. Individuals have the right to access their personal data and any such requests made to the
Committee shall be dealt with in a timely manner
4. Lawful purposes
a. All data processed by the Committee must be done on one of the following lawful bases:
consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO
guidance)
b. The Committee 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
shall be kept with the personal data
d. 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 Committee’s systems
5. Data minimisation
a. The Committee shall ensure that personal data are adequate, relevant and limited to what is
necessary in relation to the purposes for which they are processed (See Appendix 2)
6. Accuracy
a. The Committee shall take reasonable steps to ensure personal data is accurate
b. 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
7. Archiving / removal
a. To ensure that personal data is kept for no longer than necessary, the Committee shall put in
place an archiving policy for each area in which personal data is processed and review this
process annually
b. The archiving policy (See Appendix 1) shall consider what data should/must be retained, for
how long, and why
8. Security
a. The Committee shall ensure that personal data is stored securely using modern software that
is kept-up-to-date. Personal copies of data are not permitted to be taken, nor shared with
people outside of the Committee.
b. 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
c. When personal data is deleted this should be done safely such that the data is irrecoverable
d. Appropriate back-up and disaster recovery solutions shall be in place (See Appendix 2)
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 Committee shall promptly assess the risk
to people’s rights and freedoms and if appropriate report this breach to the ICO (see ICO website).
Appendix 1: Data Archiving
1. Scope
a. Names and contact details for riders, and those registering interest
b. Names and contact details for marshals
2. Policy
a. Given that the event occurs once every 2-3 years, it is reasonable to keep records from one
even until the next. These records can then form the basis for repeat events
b. Historic archives are maintained in perpetuity but are only accessible to the ongoing
committee members. These records will not be used for rider or marshal communications.
That is restricted to those contacted, and not unsubscribing, from the previous event
Appendix 2: Retained Data & Systems
1. Scope
a. Names and contact details for riders, and those registering interest
b. Names and contact details for marshals
2. Policy
a. The personal data to be retained for Marshals is limited to Name (First & Last), Contact
Telephone number(s) and email address(es)
b. The personal data to be retained for Riders is limited to Name (First & Last), Contact Telephone
number(s), email address(es) and postal address
c. Whilst postal address is not required post-ride (once rider packs distributed), other details are
needed to enable riders and marshals to be contacted for the subsequent event. As such, for
simplicity and completeness all this data is retained
d. Data is stored in Excel files (1 for Riders and 1 for Marshals) on a shared Dropbox environment.
This environment is only available to those granted access to the Dropbox environment, which
is exclusive to Committee members
Appendix 3: Information Systems
1. OneDrive: Contains rider records and other information for the current and previous events.
Data is secured via user-based access controls on a principal of minimal access to meet
requirements
2. WordPress: eCommerce system, contain all orders and customer details for the current and
previous events. Secured via MFA with only 2 user accounts
3. Mailchimp: Marketing system, contain all customer details who have authorised their details
to be retained for marketing purposes. Secured via MFA with only 2 user accounts