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Privacy Policy

Data Protection and retention policy

Overview

Key details

·         Policy prepared by Evelyn Sutherland Music on: 13 May 2018

·         Next review date: 30th April 2019

Introduction

Evelyn Sutherland Music is an organisation owned and run by Evelyn Sutherland, which organises and facilitates community choral opportunities within the local area. 

Evelyn Sutherland Music can be contacted by email at Evsutherlandmusic@hotmail.co.uk

In order to operate, Evelyn Sutherland Music, which runs the Opus 18 and  Unisong Community Choirs and the Come and Sing and Wilstead Village Voices workshops, needs to gather, store and use certain forms of information about individuals.

This can include members, contractors, suppliers, volunteers, audiences and potential audiences, business contacts and other people the group has a relationship with or regularly needs to contact.

This policy explains how this data should be collected, stored and used in order to meet Evelyn Sutherland Music data protection standards and comply with the General Data Protection Regulations (GDPR).

Why is this policy important?

This policy ensures that Evelyn Sutherland Music:

·         Protects the rights of members, volunteers and supporters of the choirs operated by Evelyn Sutherland Music

·         Complies with data protection law and follows good practice

·         Protects the group from the risks of a data breach

Role and Responsibilities

Who and what does this policy apply to?

This applies to all those handling data on behalf of Evelyn Sutherland Music.

It applies to all data that Evelyn Sutherland Music holds relating to individuals, including:

·    Names

·    Email addresses

·    Postal addresses

·    Phone numbers

·    Any other personal information held (e.g.  financial, medical)

Roles and responsibilities

Evelyn Sutherland Music is the Data Controller and will determine what data is collected and how it is used.  Any questions relating to the collection or use of data should be directed to Evelyn Sutherland Music.

Everyone who has access to data as part of Evelyn Sutherland Music has a responsibility to ensure that they adhere to this policy.

Evelyn Sutherland Music uses third part Data Processors (e.g.  Gmail, 1&1) to process data on its behalf.  Evelyn Sutherland Music will ensure all Data Processors are compliant with GDPR.


 

Data Protection Principles

a)     We fairly and lawfully process personal data in a transparent way

Evelyn Sutherland Music will only collect data where lawful and where it is necessary for the legitimate purposes of the group. 

·       A member’s name, contact details  will be collected when they first join the group, and will be used to contact the member regarding group membership administration and activities.  Other data may also subsequently be collected in relation to their membership, including their payment history for ‘subs’.  Where possible Evelyn Sutherland Music will anonymise this data.

o   Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Evelyn Sutherland Music completing tasks expected as part of the individual’s membership).

·       The name and contact details of volunteers will be collected when they take up a position and will be used to contact them regarding group administration related to their role.  Further information, including personal financial information and criminal records information may also be collected in specific circumstances where lawful and necessary (in order to process payment to the person or in order to carry out a DBS check).

o   Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Evelyn Sutherland Music completing tasks expected as part of working with the individuals).

·       An individual’s name and contact details will be collected when they make a booking for an event.  This will be used to contact them about their booking and to allow them entry to the event.

o   Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Evelyn Sutherland Music completing tasks expected as part of the booking).

·       An individual’s name, contact details and other details may be collected at any time (including when booking tickets or at an event), with their consent, in order for Evelyn Sutherland Music to communicate with them about and promote group activities (see ‘How we get consent’ below).

o   Lawful basis for processing this data: Consent (see ‘How we get consent’ below).

·       Pseudonymous or anonymous data (including behavioural, technological and geographical/regional) on an individual may be collected via tracking ‘cookies’ when they access our website or interact with our emails, in order for us to monitor and improve our effectiveness on these channels (see ‘Cookies on the Opus 18 Community Choir website’ below).

o   Lawful basis for processing this data: Consent (see ‘How we get consent’ below)

b)     We only collect and use personal data for specific, explicit and legitimate purposes and will only use the data for those specified purposes.

When collecting data, Evelyn Sutherland Music will always provide a clear and specific privacy statement explaining to the subject why the data is required and what it will be used for.

c)      We ensure any data collected is relevant and not excessive

Evelyn Sutherland Music will not collect or store more data than the minimum information required for its intended purpose.

E.g.  we need to collect telephone numbers from members in order to be able to contact them about group administration, but data on their age will not be collected, since it is unnecessary and excessive for the purposes of group administration.

d)     We ensure data is accurate and up-to-date

Evelyn Sutherland Music will ask members, volunteers and staff to check and update their data on a biennial basis.  Any individual will be able to update their data at any point by contacting Evelyn Sutherland Music.

e)     We ensure data is not kept longer than necessary

Evelyn Sutherland Music will keep records for no longer than is necessary in order to meet the intended use for which it was gathered (unless there is a legal requirement to keep records). 

The storage and intended use of data will be reviewed in line with Evelyn Sutherland Music’s data retention policy.  When the intended use is no longer applicable (e.g.  contact details for a member who has left the group), the data will be deleted within a reasonable period. 

f)      We keep personal data secure

Evelyn Sutherland Music will ensure that data held by us is kept secure.

·       Electronically-held data will be held within a password-protected and secure environment.

·       Passwords for electronic data files will be re-set each time an individual with data access leaves their role/position.

·       Physically-held data (e.g.  membership forms or email sign-up sheets) will be stored securely and will be transported in a combination locked briefcase.

·       The codes on combination locks will be changed whenever an individual with data access leaves their position.

·     Access to data will only be given to relevant volunteers and choir members where it is clearly necessary for the running of the group.  Evelyn Sutherland Music will decide in what situations this is applicable and will keep a master list of who has access to data.

g)     Transfer to countries outside the EEA

Evelyn Sutherland Music will not transfer data to countries outside the European Economic Area (EEA), unless the country has adequate protection for the individual’s data privacy rights. 

Individual Rights

When Evelyn Sutherland Music collects, holds and uses an individual’s personal data, that individual has the following rights over that data.  Evelyn Sutherland Music will ensure its data processes comply with these rights and will make all reasonable efforts to fulfil requests from an individual in relation to these rights. 

Individual’s rights

·       Right to be informed: whenever Evelyn Sutherland Music collects data it will provide a clear and specific privacy statement explaining why it is being collected and how it will be used. 

·       Right of access: individuals can request to see the data Evelyn Sutherland Music holds on them and confirmation of how it is being used.  Requests should be made by email to Evelyn Sutherland Music and will be complied with free of charge and within one month.  Where requests are complex or numerous this may be extended to two months

·       Right to rectification: individuals can request that their data be updated where it is inaccurate or incomplete.  Evelyn Sutherland Music will request that members, and contractors check and update their data on a biennial basis.  Any requests for data to be updated will be processed within one month. 

·       Right to object: individuals can object to their data being used for a particular purpose.  Evelyn Sutherland Music will always provide a way for an individual to withdraw consent in all marketing communications.  Where we receive a request to stop using data we will comply unless we have a lawful reason to use the data for legitimate interests or contractual obligation.

·       Right to erasure: individuals can request for all data held on them to be deleted.  Evelyn Sutherland Music’s data retention policy will ensure data is not held for longer than is reasonably necessary in relation to the purpose it was originally collected.  If a request for deletion is made we will comply with the request unless:

·       There is a lawful reason to keep and use the data for legitimate interests or contractual obligation. 

·       There is a legal requirement to keep the data. 

Right to restrict processing: individuals can request that their personal data be ‘restricted’ – that is, retained and stored but not processed further (e.g.  if they have contested the accuracy of any of their data, Evelyn Sutherland Music will restrict the data while it is verified). 

Though unlikely to apply to the data processed by Evelyn Sutherland Music, we will also ensure that rights related to portability and automated decision making (including profiling) are complied with where appropriate.

 

Member to Member Contact

We only share members’ data with other members with the subject’s prior consent

As a membership organisation Evelyn Sutherland Music encourages communication between members of the choirs operated by Evelyn Sutherland Music. 

To facilitate this:

·       Members can request the personal contact data of other members by emailing Evelyn Sutherland Music.  These details will be given, as long as they are for the purposes of contacting the subject (e.g.  an email address, not financial or health data) and the subject has consented to their data being shared with other members in this way

How we get consent

Evelyn Sutherland Music will from time to time collect data from consenting supporters for marketing purposes.  This includes contacting them to promote performances, updating them about group news, fundraising and other group activities.

Any time data is collected for this purpose, we will provide:

·       A method for users to show their positive and active consent to receive these communications (e.g.  a ‘tick box’)

·       A clear and specific explanation of what the data will be used for (e.g.  ‘I would like to receive information about selected events which may be of interest to choir members by email’)

Data collected will only ever be used in the way described and consented to (e.g.  we will not use email data in order to market 3rd-party products unless this has been explicitly consented to).

Every marketing communication will contain a method through which a recipient can withdraw their consent (e.g.  an ‘unsubscribe’ link in an email).  Opt-out requests such as this will be processed within 14 days.

Cookies on the Opus 18 Community Choir website

A cookie is a small text file that is downloaded onto ‘terminal equipment’ (e.g.  a computer or smartphone) when the user accesses a website.  It allows the website to recognise that user’s device and store some information about the user’s preferences or past actions.

Opus 18 Community Choir does not use cookies on it’s website (www.opus18communitychoir.org.uk) to monitor and record the activity of website users.

 Data retention policy

Overview

Introduction

This policy sets out how Evelyn Sutherland Music will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary.

It forms part of Evelyn Sutherland Music Data Protection Policy.

Roles and responsibilities

Evelyn Sutherland Music is the Data Controller and will determine what data is collected, retained and how it is used.  Any questions relating to data retention or use of data should be directed to Evelyn Sutherland Music.

Regular Data Review

A regular review of all data will take place to establish if Evelyn Sutherland Music still has good reason to keep and use the data held at the time of the review.

As a general rule a data review will be held every two years and no more than 27 calendar months after the last review.  The first review will take place on 2nd May 2018.

Data to be reviewed

·       Evelyn Sutherland Music stores data on digital documents (e.g.  spreadsheets) stored on personal devices.

·       Data stored on third party online services (e.g.  Gmail, 1&1).

·       Physical data stored at the homes of volunteers.

Who the review will be conducted by?

The review will be conducted by Evelyn Sutherland Music with other volunteers to be decided on at the time of the review.

How data will be deleted?

·       Physical data will be destroyed safely and securely, including shredding.

·       All reasonable and practical efforts will be made to remove data stored digitally.

o   Priority will be given to any instances where data is stored in active lists (e.g.  where it could be used) and to sensitive data.

o   Where deleting the data would mean deleting other data that we have a valid lawful reason to keep (e.g.  on old emails) then the data may be retained safely and securely but not used.

Criteria

The following criteria will be used to make a decision about what data to keep and what to delete.

Question

Action

Yes

No

Is the data stored securely?

 

No action necessary

Update storage protocol in line with Data Protection policy

Does the original reason for having the data still apply?

 

Continue to use

Delete or remove data

Is the data being used for its original intention?

 

Continue to use

Either delete/remove or record lawful basis for use and get consent if necessary

Is there a statutory requirement to keep the data?

Keep the data at least until the statutory minimum no longer applies

Delete or remove the data unless we have reason to keep the data under other criteria. 

Is the data accurate?

Continue to use

Ask the subject to confirm/update details

Where appropriate do we have consent to use the data.  This consent could be implied by previous use and engagement by the individual

Continue to use

Get consent

Can the data be anonymised

Anonymise data

Continue to use

 

Statutory Requirements

Date stored by Evelyn Sutherland Music may be retained based in statutory requirements for storing data other than data protection regulations.  This might include but is not limited to:

·       Gift Aid declarations records.

·       Details of payments made and received (e.g.  in bank statements and accounting records).

·       Contracts and agreements with suppliers/customers.

·       Insurance details.

·       Tax and employment records.

Other data retention procedures

Member data

·       When a member leaves a choir operated by Evelyn Sutherland Music and all administrative tasks relating to their membership have been completed any potentially sensitive data held on them will be deleted – this might include bank details or medical data.

·       Unless consent has been given data will be removed from all email mailing lists.

·       All other data will be stored safely and securely and reviewed as part of the next biennial review.

Mailing list data

·       If an individual opts out of a mailing list their data will be removed as soon as is practically possible.

·       All other data will be stored safely and securely and reviewed as part of the next biennial review.

Volunteer and freelancer data

·       When a volunteer or freelancer stops working with Evelyn Sutherland Music and all administrative tasks relating to their work have been completed any potentially sensitive data held on them will be deleted – this might include bank details or medical data.

·       Unless consent has been given data will be removed from all email mailing lists.

·       All other data will be stored safely and securely and reviewed as part of the next biennial review.

Other data

·       All other data will be included in a regular biennial review.

Contacting Evelyn Sutherland Music

Any questions concerning this policy or data held by Evelyn Sutherland Music should be sent by email to Evsutherlandmusic@hotmail.co.uk