Privacy Policy - Leicester Bach Choir

Privacy Policy – The Leicester Bach Choir Website

This privacy policy sets out how Leicester Bach Choir uses and protects any information that you give when you use this website.
Leicester Bach Choir is committed to ensuring that your privacy is protected. If we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement. We may revise these terms and conditions at any time by updating this posting. You should check this website from time to time to review the then current terms and conditions, because they are binding on you. Certain provisions of these terms and conditions may be superseded by expressly designated legal notices or terms located on particular pages of this website. If you do not wish to accept any new terms and conditions after we have given notice, you should not continue to use this website.

What we collect

We may collect the following information:

Name
Contact information including email address if relevant
Demographic information such as postcode, preferences and interests

What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

Internal record keeping
We may use the information to improve our service
We may periodically send emails about choir concerts and events which we think you may find interesting using the email address you have provided.
We may use the information to customise the website according to your interests
We collect your data when you make an enquiry. We store this data for our records so we know who we have been in contact with. We do not share this data with anyone else

Security

We’re committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. All data is stored securely.

How we use cookies

A cookie is a small file placed on your computer’s hard drive that helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual and tailor its operations by gathering and remembering information about your preferences. We only use this information for statistical analysis purposes and then data is removed from the system. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie does not give us access to your computer or any information about you, other than the data you choose to share with us. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Third-Party Websites

Certain content available via our website may include material from third-party websites. Links on this site may also direct you to third-party websites that are not affiliated with us. We are not responsible for the content or its accuracy and we do not warrant and will not have any liability or responsibility for any third-party materials or websites, or for any other materials, products, or services of third-parties. Please review carefully the third-party’s policies and practices and make sure you understand them before you engage in any transaction. Complaints, claims, concerns, or questions regarding third-party products should be directed to the third-party. Users who decide to access these sites via our links do so at their own risk.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

Whenever you are asked to fill in a form on our website, look for the box that you can click to confirm your preferences for the way your information is to be used. You may change your mind at any time by writing to or emailing us.
We will not sell, distribute or lease your personal information to third parties.

You may request details of personal information which we hold about you under the Data Protection Act 1998. If you would like a copy of the information held on you please email us. If you believe that any information we hold on you is incorrect or incomplete, please email us. We will promptly correct any information found to be incorrect.

Leicester Bach Choir Data Protection Policy

Overview

Key details

Policy prepared by: Ian Bloor
Approved by Board / Committee on: 08/07/2019
Next review date: 02/05/2020

Introduction

In order to operate, the Leicester Bach Choir needs to gather, store and use certain forms of information about individuals. These can include members, employees, 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 the Leicester Bach Choir’s data protection standards and comply with the General Data Protection Regulations (GDPR).

Why is this policy important?

This policy ensures that the Leicester Bach Choir:

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 & Responsibilities

Who and what does this policy apply to?

This applies to all those handling data on behalf of the Leicester Bach Choir e.g.:

Committee members
Employees and volunteers
Members
Contractors / 3rd-party suppliers

It applies to all data that the Leicester Bach Choir holds relating to individuals, including:

Names
Email addresses
Postal addresses
Phone numbers
Any other personal information held (e.g. financial)

Roles and responsibilities

The Leicester Bach Choir is the Data Controller and will determine what data is collected and how it is used. The Data Protection Officer for the Leicester Bach Choir is Ian Bloor. They, together with the Leicester Bach Choir Committee, are responsible for the secure, fair and transparent collection and use of data by the Leicester Bach Choir. 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 the Leicester Bach Choir has a responsibility to ensure that they adhere to this policy.
The Leicester Bach Choir uses third party Data Processors (e.g. Dropbox) to process data on its behalf. The Leicester Bach Choir will ensure all Data Processors are compliant with GDPR.

Data Protection Principles

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

The Leicester Bach Choir will only collect data where lawful and where it is necessary for the legitimate purposes of the group.

A member’s name and 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 the Leicester Bach Choir will anonymise this data.
- Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to the Leicester Bach Choir completing tasks expected as part of the individual’s membership).
The name and contact details of volunteers, employees 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).
- Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to the Leicester Bach Choir 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.
- Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to the Leicester Bach Choir 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 the Leicester Bach Choir to communicate with them about and promote group activities. See ‘How we get consent’ below.
- 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, the Leicester Bach Choir 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

The Leicester Bach Choir will not collect or store more data than the minimum information required for its intended purpose.

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

The Leicester Bach Choir 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

The Leicester Bach Choir 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 the Leicester Bach Choir’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

The Leicester Bach Choir 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 Gift Aid forms) will be stored in an appropriate manner to prevent unauthorised access (e.g. in a cabinet or folder at the home of the relevant Committee member.)
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

The Leicester Bach Choir 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 the Leicester Bach Choir collects, holds and uses an individual’s personal data that individual has the following the rights over that data. The Leicester Bach Choir 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 the Leicester Bach Choir 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 the Leicester Bach Choir 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. The Leicester Bach Choir 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. The Leicester Bach Choir 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. The Leicester Bach Choir’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, the Leicester Bach Choir will restrict the data while it is verified).

Though unlikely to apply to the data processed by the Leicester Bach Choir, 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.

How we get Consent

The Leicester Bach Choir will regularly 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. ‘Tick this box if you would like the Leicester Bach Choir 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).

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.

Data retention policy

Overview

Introduction

This policy sets out how the Leicester Bach Choir will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary.

It forms part of the Leicester Bach Choir Data Protection Policy.

Roles and responsibilities

The Leicester Bach Choir is the Data Controller and will determine what data is collected, retained and how it is used. The Data Protection Officer for the Leicester Bach Choir is Ian Bloor. They, together with the Leicester Bach Choir Committee are responsible for the secure and fair retention and use of data by the Leicester Bach Choir. 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 the Leicester Bach Choir 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 took place in May 2018.

Data to be reviewed

The Leicester Bach Choir stores

Data on digital documents (e.g. spreadsheets) stored on personal devices held by committee members
Data stored on third party online services (e.g. Dropbox)
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.
- 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. 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 the Leicester Bach Choir 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)
Minutes of Committee meetings and Trustee meetings
Contracts and agreements with suppliers/customers
Insurance details

Other data retention procedures

Member data

When a member leaves the Leicester Bach Choir and all administrative tasks relating to their membership have been completed any potentially sensitive data held on them will be deleted – this might include financial 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

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 the Leicester Bach Choir 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.