Monday, 2 April 2018

The GDPR is coming...

This is a very dry and dull post, but necessary because of the change in data protection legislation coming in next month.
From 25th May 2018, any business, organisation or group holding personal information about living people in the UK or European Union, will have to conform to the General Data Protection Regulation. This is to prevent misuse of personal data.

During the time I have been co-ordinating the Fitzhenry and Fitzharris One Name Study and DNA project, I have acquired quite a lot of data about living people. So I am going to tell you how I come by that information, how I store it, how I share it, and how you can find out what I hold about you. I hope you think it is an acceptable way of managing a global family history study..

Please note this legislation only concerns living people. So if someone died a hundred years ago, or yesterday, they are not covered by this legislation. However I will be sensitive to the information I release on the more recently deceased when it may affect their surviving family.

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1. The website and the genealogy database contains all the information I have collected over nearly 20 years of conducting this study. The information generally comes to me in 3 ways:

1.1 It is information in the public domain, and I have found it in newspapers and websites and other public areas. Examples are birth notices, obituaries, reports of news events, sporting achievements.
What do I do with this information?
I enter it into the Fitzhenry and Fitzharris database for each individual it pertains to.
This helps me build up a picture of the population of people carrying the name Fitzhenry and Fitzharris, and which lines may have died out.
If a person writes to me with an enquiry about their Fitzhenry or Fitzharris ancestors (see below), I can use information about the present day families to link back to their ancestors.
Sometimes I use it as the basis for a Blog entry (see here for when I wrote about the author Lindsey Fitzharris) or the congratulating people on their achievements (the Devon branch of the Fitz-Henry family swimming the channel).

1.2 People have written to me or emailed me and asked about tracing their Fitzhenry or Fitzharris ancestors. In the course of this, they will have told me things about themselves and their immediate family to start the search. Obviously the person who has written to me knows that they have shared the information, but the people they have mentioned may not know.
What do I do with this information?
I save all emails relating to the one name study.
The information which is given to me is entered into the Fitzhenry/Fitzharris database.
If it is sensitive information (whether about a living or deceased person), it is marked as Private, meaning that is is not for sharing with others or for putting on the website or discussing in the Blog.
If it concerns a living person or people, that individual is marked as Living and it does not get uploaded to any online family tree that I may use. 
At the time of writing this I have editing rights to Wikitrees, the FamilySearch database and my own online database at FitzhenryDNA.com. 
I also expect to upload my entire database for permanent archiving to the Members Website Project at the Guild of One Name Studies.

1.3 Data collected from Genealogy database sites (such as Ancestry, FamilySearch or Find My Past).
These sites contains data sets which will sometimes contain details about living people, although this may be under review because of the GDPR.
What do I do with this information?
It is entered into the Fitzhenry and Fitzharris database.
As noted above, living individuals are marked as Living and those details are not shared further on my published databases.

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2. The Fitzhenry and Fitzharris DNA (FHDNA) study at FamilyTreeDNA (FTDNA).
I have been project co-ordinator for this study for 10 years.
Genetic genealogy has revolutionised how we can show kinship with people descended from a distant common ancestor and link seemingly disparate Fitzhenry and Fitzharris lines.
There are 4 categories of people (testers) who have their DNA and other personal data under the umbrella of the FHDNA study.

2.1 Testers who had already taken the test, then have joined the FHDNA project. 
I can see their results and match lists.
I have basic contact details for them which they entered on their FTDNA profile.
I send them a "Welcome to the project" email, but no further communication if they do not respond.
If they leave the project, I can no longer see any details about them or their test results.

2.2 Potential testers who ask my advice about DNA testing in regard to their particular Fitzhenry and Fitzharris family line before ordering a test.
As for (2.1), plus I treat all information gathered through these communications as per (1.2 - direct communication)

2.3 Tests I manage on behalf of other people.
As for (2.1) and (2.2) plus managing incoming enquiries or ordering supplementary tests.
Enquiries are always passed to the tester involved to deal with, or for me to reply to after discussion with that tester.
Supplementary tests are ordered after discussion with that tester regardless of who is paying for them. The person who the DNA belongs to makes the final decision on this.

2.4 DNA tests of deceased participants
A few of our FHDNA project members have died since the project started. Most of these expressed the view that their results should be used to further Fitzhenry and Fitzharris research, for which I am very grateful and I continue to manage their tests according to their wishes. For those deceased people who expressed no such wishes, the test results have lain dormant. 

ISOGG (the International Society for Genetic Genealogists) has put their position statement on their website. I believe I fully comply with the standards contained in this statement. For the privacy statement I use in the FHDNA study, please see slide 12 of the ISOGG powerpoint presentation.

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3. Data Security
3.1 I use strong passwords for access to my laptop on which my genealogy software and the Fitzhenry and Fitzharris database are installed.

3.2 The Fitzhenry and Fitzharris database is stored in cloud storage (Dropbox) which is also password protected. 

3.3 The Fitzhenry and Fitzharris database online at FitzhenryDNA.com is password protected. 
There is no information about living people uploaded to this online database.
Guest users see the minimum of information held on deceased people (birth, marriages and deaths).
Approved subscribers have access to full information about deceased people in the database.
I hold contact details for the approved subscribers which they entered when applying for access to the database. In addition they optionally enter which Fitzhenry or Fitzharris line they are related to. 
Neither the genealogy database nor the subscriber database is searchable by bots.

3.4 I freely share information about deceased people with people who legitimately enquire about their family history, and other historical researchers.
I will not divulge information I hold on any other living person, unless that information is already in the public domain (See section 1.1) or that person has given me express and unrevoked permission to share specified information.
If I am asked for contact details of a living person, I will not supply them. 
Instead, I will ask the enquirer if they agree to me forwarding on their own contact details, and do that when permission is expressly given.

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4. How do I find out what information you hold about me?
I am very happy for you to email me at fitz-henry@one-name.org
I will respond to you within 48 hours, giving you a time frame for when I will be able to supply you with the information. (I co-ordinate these projects single handedly, and I may be away from access to the databases and hard copies of information).

Well done with staying right to the end!
If you have any general queries about how this legislation affects your contact with the Fitzhenry and Fitzharris study, please use the comments section and I will try to answer them within my understanding of the GDPR.


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