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Data Protection and Privacy Policy

Data Protection & Privacy Policy

Key details

  • Policy prepared by: Reigate & Redhill Choral Society (RRCS)
  • Approved by Trustees on: 24/05/2018
  • Next review date: 23/05/2020


Introduction

In order to operate RRCS needs to gather, store and use certain forms of information about individuals.

These can include members, friends, 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 RRCS data protection requirements and comply with the General Data Protection Regulations (GDPR).


Why is this policy important?

This policy ensures that RRCS:

Protects the rights of our members, audiences, supporters and contractors

Complies with data protection law and follows good practice

Protects RRCS from the risks of a data breach


Roles and responsibilities

RRCS is the Data Controller and will determine what data is collected and retained and how it is used. The Data Protection Officer is the Membership Secretary. They, together with the Committee, all members and contractors/third party suppliers who handle data on behalf of RRCS are responsible for the secure and fair retention and use of data by RRCS. Any questions relating to the collection or use of data should be directed to the Data Protection Officer.


Information collected

Personal information collected may include: name, gender, contact information, occupation, current/former employers, age group and bank account details.

We do not seek any sensitive information about you unless legally required for recruitment purposes.  Sensitive information includes data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual orientation or criminal record. 

 

Data protection principles

We fairly and lawfully process personal data in a transparent way

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

An individual’s name, gender, contact information, occupation, current/former employers and age group will be collected when they join the choir. This will be used for membership purposes. Name and contact details will be supplied where people opt to receive marketing information. Bank details will be supplied by those who opt to receive electronic payments.

The lawful basis for processing this data is that the collection and use of data is fair and reasonable in relation to managing RRCS membership and marketing.

An individual’s name, contact details and other details may be collected at any time, with their consent, in order for RRCS 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, social media sites or interact with our emails, in order for us to monitor and improve our effectiveness on these channels. See ‘Cookies on the RRCS website below.

We ensure any data collected is relevant and not excessive

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

We ensure data is accurate and up-to-date

RRCS will ask members and others 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.

We ensure data is not kept longer than necessary

RRCS 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 RRCS’ data retention policy, see below. 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.  

We keep personal data secure

RRCS 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 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.

Transfer to countries outside the EEA

RRCS 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 RRCS collects, holds and uses an individual’s personal data that individual has the following rights over that data. RRCS 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:

Right to be informed: an explanation of why data is collected and how it will be used.

Right of access: individuals can request to see the data RRCS 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 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. RRCS will request that members, those on marketing lists 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. RRCS 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. RRCS 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 or 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, RRCS will restrict the data while it is verified).


How we get consent

RRCS collects personal information when people join the choir. At that point they are asked to agree, by signing a form, that the information provided may be used for membership purposes.

RRCS will regularly collect data from consenting supporters for marketing purposes. This includes contacting them to promote performances and updating them about group news and 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’) and also a clear and specific explanation of how the data will be used.

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 consent has been given explicitly).

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 one month.


Cookies on our website

With regard to each of your visits to our site we will automatically collect the following personal data by using cookies.  Please see our Cookie Notice for further details:

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including items you viewed or searched for, page response times, length of visits to certain pages.  

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.

RRCS uses cookies to monitor and record users’ 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 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).


Data Retention

RRCS will establish processes to ensure we do not hold data for longer than is necessary.

A regular review of all data will take place to establish if RRCS 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 on 25 May 2018.

RRCS has data stored on digital documents (e.g. spreadsheets) stored on personal devices held by committee members; data stored on third party online services, and physical data stored at the homes of responsible members.

The review will be conducted by the Data Protection Officer with other committee members to be decided on at the time of the review.

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).

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

 

When a member leaves RRCS 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.

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.

 

RRCS

24 May 2018

Preview

Click here to preview repertoire.

Download the 2017-18 brochure here.

2017 / 18 Dates

Tues 12/26 Sept.

OPEN REHEARSALS

 

Sat 28 Oct.

RUTTER WORKSHOP

 

Sat 11 Nov.

REMEMBRANCE CLASSICS

 

Tues 5 Dec.

FESTIVAL OF CAROLS

 

Sat 9 Dec.

CHRISTMAS CLASSICS

 

Tues 16/23/30 Jan.

OPEN REHEARSALS

 

Sat 10 Mar.

REFLECTIONS

 

Sun 22 Apr.

GREENWICH CLASSICS

 

Sat 5-Mon 7 May

EUROPEAN TOUR

 

Sat 7 Jul.

A NIGHT AT THE OPERA