Data Protection policy
Overview
Key details
· Policy prepared by: Corelli Ensemble
· Approved by Board/committee on: 13/05/2018
· Next review date: 10/05/2020
Introduction
In order to operate, Corelli Ensemble
needs to gather, store and use certain forms of information about individuals.
These can include members, 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 Corelli Ensemble data
protection standards and comply with the General Data Protection Regulations
(GDPR).
Why
is this policy important?
This policy ensures that Corelli
Ensemble:
· Protects the rights of our members, volunteers and supporters
· Complies with data protection law and follows good practice
· Protect 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 Corelli Ensemble e.g.:
· Committee members
· Employees and volunteers
· Members
· Contractors/3rd-party suppliers
It applies to all data that Corelli Ensemble holds
relating to individuals, including:
· Names
· Email addresses
Roles
and responsibilities
Corelli Ensemble is the Data
Controller and will determine what data is collected and how it is used. The Data
Protection Officer for Corelli Ensemble is [name]. They, together with the Committee,
are responsible for the secure, fair and transparent collection and use of data
by Corelli Ensemble .Any questions relating to the collection or use of data
should be directed to the Data Protection Officer.
Everyone who has
access to data as part of Corelli Ensemble has a responsibility to ensure that
they adhere to this policy.
Data protection principles
a) We
fairly and lawfully process personal data in a transparent way
Corelli Ensemble will only
collect data where lawful and where it is necessary for the legitimate purposes
of the group.
· 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 Corelli
Ensemble 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 Corelli Ensemble 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’)
· 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 Corelli
Ensemble website’ below.
o Lawful basis for processing this data: Consent (see
‘How we get consent’)
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, Corelli
Ensemble 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
Corelli Ensemble 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 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
Corelli Ensemble will ask
members, volunteers and staff to check and update their data on an annual basis. Any individual will 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
Corelli Ensemble 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 Corelli Ensemble’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
Corelli Ensemble 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 in a locked cupboard
· Keys for locks securing physical data files should be collected by the
Data Protection Officer from any individual with access if they leave their
role/position. The codes on combination locks should be changed each time an
individual with data access leaves their role/position
· Access to data will only be given to relevant trustees/committee 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
Corelli Ensemble 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 Corelli Ensemble collects, holds and uses an individual’s personal
data that individual has the following rights over that data. Corelli Ensemble 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 Corelli Ensemble 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 Corelli Ensemble holds on them
and confirmation of how it is being used. Requests should be made in writing 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. Corelli Ensemble will request that
members, staff and contractors check and update their 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.
Corelli Ensemble 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. Corelli
Ensemble’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, Corelli Ensemble will
restrict the data while it is verified).
Though unlikely to apply to the
data processed by Corelli Ensemble, we will also ensure that rights related to portability
and automated decision making (including profiling) are complied with where
appropriate.
How we get consent
Corelli Ensemble will regularly collect data from consenting
supporters for marketing purposes. This includes contacting them to promote performances,
updating them about group news 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 Corelli Ensemble to send you email updates
with details about our forthcoming events’)
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 Corelli Ensemble 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.
Corelli Ensemble uses cookies on our website www.corelliensemble.co.uk in order to monitor and record their 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 will implement a pop-up box
on [www.mygroup.com] 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 Privacy Policy which outlines which specific cookies are used and how
cookies can be disabled in the most common browsers.
Data retention policy
Overview
Introduction
This policy sets out how Corelli
Ensemble will approach data retention and establishes processes to
ensure we do not hold data for longer than is necessary.
It forms part of Corelli Ensemble
Data Protection Policy.
Roles
and responsibilities
Corelli Ensemble is the Data
Controller and will determine what data is collected, retained and how it is
used. The Data Protection Officer for Corelli Ensemble is [name]. They,
together with the Committee are responsible for the secure and fair
retention and use of data by Corelli Ensemble. 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 Corelli Ensemble 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 took place on 20 May 2018.
Data
to be reviewed
· Corelli Ensemble stores data on digital documents (e.g. spreadsheets)
stored on personal devices held by committee members.
· Data stored on third party online services, Free Virtual Server
· Physical data stored at the homes of committee members
Who
the review will be conducted by
The review will be conducted by
the Data Protection Officer with other committee 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.
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 |
Other data retention procedures
Member
data
· When a member leaves Corelli Ensemble and all administrative tasks
relating to their membership have been completed any potentially sensitive data
held on them will be deleted
· 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
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
Other
data
· All other data will be included in a regular two year
review.
|