Data Protection & Privacy policy

Data protection policy

Overview

Key details
  • Policy prepared by: Valerie Thompson
  • Approved by Board/committee on: 29/06/2018
  • Next review date: June 2020

In order to operate as a choir that rehearses and gives regular performances, we need to collect, store and use certain forms of information about individuals. These can include members of the choir, contractors, suppliers, audiences and potential audiences, business contacts, and other people the charity 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 Ember Choral data protection standards and comply with the General Data Protection Regulations (GDPR).

Why is this policy important?

This policy ensures that Ember Choral:

  • Protects the rights of our members, volunteers and supporters
  • Complies with data protection law and follows good practice
  • Protects the group from the risks of a data breach

Roles and responsibilities

Who and what does this policy apply to?

This applies to all those handling data on behalf of Ember Choral e.g.:

  • Trustees and Committee members
  • Members
  • Volunteers
  • Contractors/3rd-party suppliers

It applies to all data that Ember Choral holds relating to individuals, including:

  • Names
  • Email addresses
  • Postal addresses
  • Phone numbers
  • Any other personal information held (e.g. Gift Aid, bank details, photos/video footage)
Roles and responsibilities

Ember Choral is the Data Controller and will determine what data is collected and how it is used. The Data Protection Officer for Ember Choral is Valerie Thompson. She, together with the Committee, is responsible for the secure, fair and transparent collection and use of data by Ember Choral. Any questions relating to the collection or use of data should be directed to the Data Protection Officer (or via info(Replace this parenthesis with the @ sign)emberchoral.org.uk).

Everyone who has access to data as part of Ember Choral has a responsibility to ensure that they adhere to this policy.

Where Ember Choral uses third party Data Processors (such as Mail Chimp) to process data on its behalf then it will ensure that all those Data Processors are also compliant with GDPR.

Data protection principles

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

Ember Choral will only collect data where lawful and where necessary for the legitimate purposes of the group.

  • A member’s name, postal address, personal email address, and other contact details will be collected when they first join the choir, and will be used to contact the member regarding membership administration and activities. Other data may also subsequently be collected in relation to their membership, including their payment history for ‘subs’. Where possible Ember Choral will anonymise this data.
  • We have a legal responsibility to retain all records related to Gift Aid claims for a period of 6 years.
  • The name and contact details of volunteers and contractors 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).
  • An individual’s name and contact details may be collected when they make an online booking for an event. This will be used to process their purchase of a ticket, and contact them about their booking, and to allow them entry to the event.
  • 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 Ember Choral to communicate with them about and promote group activities. 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 Ember Choral website below. Consent (see ‘How we get consent’ later).
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, Ember Choral 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

Ember Choral will not collect or store more data than the minimum information required for its intended purpose. For example we need to collect telephone numbers from members in order to be able to contact them about group administration, and email addresses to tell them about the activities of the choir, but data on their marital status or sexuality 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

Ember Choral will ask members, volunteers and staff to check and update their data on an annual basis.  Any individual will also be able to update their data at any point by contacting the Data Protection Officer. 

e) We ensure data is not kept longer than necessary

Ember Choral 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 Ember Choral’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

Ember Choral 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.
  • Access to data will only be given to relevant trustees/committee members/members/contractors where it is clearly necessary for the running of the group. The Data Protection Officer 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

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

Individual’s rights
  • Right to be informed: whenever Ember Choral 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 that Ember Choral holds on them and confirmation of how it is being used. Requests should be made by email to the Data Protection Officer 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. Ember Choral will request that members, staff and contractors check and update their own data on an annual 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. Ember Choral 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. Ember Choral’s data retention policy will ensure data is not held for longer than is reasonably necessary in relation to the purpose for which 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, Ember Choral will restrict the data while it is verified).

Though unlikely to apply to the data processed by Ember Choral, 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 Ember Choral encourages communication between members. To facilitate this, members can request the personal contact data of other members by email via the Data Protection Officer or Membership Secretary. These details will be given, as long as they are for the purposes of contacting the subject (e.g. an email address, not financial data) and the subject has consented to their data being shared with other members in this way.

How we get consent

Ember Choral will sometimes collect data from consenting supporters for marketing purposes. This includes contacting them to promote concerts, 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. ‘Tick this box if you would like Ember Choral to send you email updates with details about our forthcoming events, fundraising activities and opportunities to get involved’)

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).

Cookies on the Ember Choral 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.

Ember Choral uses cookies on our website www.emberchoral.org.uk in order to monitor and record activity. This allows us to improve users’ experience of our website by, for example, allowing for a ‘logged in’ state, and by giving us useful insight into how users as a whole are engaging with the website.

We have implemented a pop-up box on www.emberchoral.org.uk that will activate each new time a user visits the website. This will allow them to click to consent (or not) to continuing with cookies enabled, or to ignore the message and continue browsing (i.e. give their implied consent).

It will also include a link to our Data Protection and Privacy Policy which outlines which specific cookies are used and how cookies can be disabled in the most common browsers.  Information about the website’s use of cookies can be accessed here.


Data retention policy

Overview

Introduction

This policy sets out how Ember Choral will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary. It forms part of Ember Choral’s Data Protection Policy.

Roles and responsibilities

Ember Choral is the Data Controller and will determine what data is collected, retained and how it is used. The Data Protection Officer for Ember Choral is Valerie Thompson. She, together with the Committee, is responsible for the secure and fair retention and use of data by Ember Choral. Any questions relating to data retention or use of data should be directed to the Data Protection Officer.

Regular data review

A regular review of all data will take place to establish if Ember Choral 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 2 years and no more than 27 calendar months after the last review. The first review will take place in June 2020.

Data to be reviewed
  • Ember Choral stores data on digital documents (e.g. spreadsheets) stored on personal devices held by Committee members and other members who have administration roles with the choir
  • Data collected through our website
  • Data stored on third party online services [(e.g. Google Drive, Mail Chimp, POWr)]
  • Physical data stored at the homes of relevant members
Who the review will be conducted by

The review will be conducted by the Data Protection Officer with other members 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.
    • 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.
    • Where deleting the data would mean deleting other data that we have a valid lawful reason to keep (e.g. in 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

Other data retention procedures

Member data
  • When a member leaves Ember Choral, 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
  • 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 two year review
  • Where there is a legal requirement to retain data (e.g. Gift Aid records must be held for 6 years) then that will override all other preferences
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 two year review
Volunteer and freelancer data
  • When a volunteer or freelancer stops working with Ember Choral 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 two year review
Other data
  • All other data will be included in a regular two year review.

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